ANALOG DEVICES, INC. & SUBS. v. COMMISSIONER

Docket No. 17380-12.

147 T.C. 429 (2016)

147 T.C. No. 15

ANALOG DEVICES, INC. & SUBSIDIARIES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 22, 2016.


Attorney(s) appearing for the Case

Kenneth B. Clark, James P. Fuller, Jennifer L. Fuller, Andrew J. Kim, and Larissa B. Neumann, for petitioner.

Michele J. Gormley and Curt M. Rubin, for respondent.


OPINION

Respondent determined deficiencies in petitioner's Federal income tax of $3,997,804 and $22,112,640 for taxable years 2006 and 2007, respectively. The issue for decision is whether the accounts receivable that the parties established in a 2009 closing agreement pursuant...

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