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W.L. GORE & ASSOCIATES, INC. v. COMMISSIONER

Docket No. 15476-93.

69 T.C.M. 2037 (1995)

T.C. Memo. 1995-96

W.L. Gore & Associates, Inc. v. Commissioner.

United States Tax Court.

Filed March 7, 1995.

Attorney(s) appearing for the Case

Robert E. Schlusser, Bryan E. Keenan, 1700 W. 14th St., Wilmington, Del., and John S. Campbell, for the petitioner. Richard H. Gannon, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

This case is before us on petitioner's motion for summary judgment under Rule 121.1 Respondent determined the following deficiencies in petitioner's Federal income taxes based upon the allocation of royalty income to petitioner from Japan Gore-Tex, Inc. (JGT), pursuant to the provisions of section 482:

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