CGG AMERICAS, INC. v. COMMISSIONER

Docket No. 25097-10.

147 T.C. 78 (2016)

147 T.C. No. 2

CGG AMERICAS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 21, 2016.


Attorney(s) appearing for the Case

Allen Duane Webber, Thomas V. Linguanti, Summer M. Austin, Sonja Schiller, and Phillip J. Taylor, for petitioner.

Dennis M. Kelly, Robert M. Morrison, and Shelia Dansby Harvey, for respondent.


OPINION

We will grant the motion for summary judgment filed by the petitioner, CGG Americas, Inc. ("CGGA"), on July 23, 2012. We will deny the cross-motion for summary judgment filed by the respondent (the "IRS") on July 25, 2012.

The IRS issued a notice of deficiency to CGGA determining income-tax deficiencies...

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