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HITACHI SALES CORPORATION OF AMERICA v. COMMISSIONER

Docket No. 21663-90.

69 T.C.M. 1958 (1995)

T.C. Memo. 1995-84

Hitachi Sales Corporation of America v. Commissioner.

United States Tax Court.

Filed February 27, 1995.

Attorney(s) appearing for the Case

Nancy L. Iredale and Robert A. Earnest, for the petitioner. Anne Hintermeister, Frances Ferrito Regan, and Steven R. Winningham, for the respondent.

Supplemental Memorandum Opinion

HALPERN, Judge:

This matter is before the Court on respondent's motion for summary judgment, filed July 20, 1994 (the present motion), concerning a section 481 adjustment. This is the third report that the Court has made in this case. Our two prior reports are Hitachi Sales Corp. of America v. Commissioner [Dec 48,470(M)], T.C. Memo. 1992-504 (Hitachi I), supplemented by Hitachi...

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