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SUN MICROSYSTEMS, INC. v. COMMISSIONER

Docket No. 8976-91.

66 T.C.M. 997 (1993)

T.C. Memo. 1993-467

Sun Microsystems, Inc. & Consolidated Subsidiaries v. Commissioner.

United States Tax Court.

Filed October 5, 1993.

Attorney(s) appearing for the Case

Andre M. Saltoun, Dennis I. Meyer, A. Duane Webber, and Wright H. Schickli, 2 Embarcadero Center, San Francisco, Calif. for the petitioners. Jeffrey L. Heinkel and Steven A. Wilson, for the respondent.

Memorandum Findings of Fact and Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' 1987 Federal income tax return in the amount of $4,351,585. The issues relating to stock warrants (the warrants), the subject of this opinion, have been severed from certain other issues. Thus, the issue presented for our consideration is whether the warrants issued by petitioners, when exercised, constitute sales discounts the value of which is...

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