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HEWLETT-PACKARD CO. & CONSOL. SUBS. v. COMM'R

Docket Nos. 21976-07, 10075-08.

139 T.C. 255 (2012)

HEWLETT-PACKARD COMPANY AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 24, 2012.

Attorney(s) appearing for the Case

Albert H. Turkus and Paul Oosterhuis, for petitioner.

David P. Fuller and Roger L. Kave, for respondent.

OPINION

GOEKE, Judge:

In two statutory notices of deficiency respondent disallowed in part credits for increasing research activities pursuant to section 411 claimed by petitioner, Hewlett-Packard Co. & Consolidated Subsidiaries (HP), for taxable years 1999 through 2003. Following concessions and stipulations, the parties cross-moved for partial summary judgment on two issues...

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