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BMC SOFTWARE INC. v. COMMISSIONER

Docket No. 15675-11.

141 T.C. 224 (2013)

BMC SOFTWARE INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 18, 2013.

Attorney(s) appearing for the Case

George Matthew Gerachis , Christine L. Vaughn , and Lina G. Dimachkieh , for petitioner.

Daniel L. Timmons , for respondent.

KROUPA, Judge:

Respondent determined a $13 million1 deficiency in petitioner's Federal income tax resulting from his interpretation of section 965,2 a one-time dividends received deduction for a U.S. corporation. The amount qualifying for the dividends received deduction is reduced by increased related party indebtedness under section 965(b)(3) (sometimes, related party debt rule). We must decide for...

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