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ALTERA CORP. & SUBS. v. COMMISSIONER

Docket Nos. 6253-12, 9963-12.

145 T.C. 91 (2015)

ALTERA CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 27, 2015.

Attorney(s) appearing for the Case

Andrew P. Crousore, Donald M. Falk, Joseph B. Judkins, Thomas Lee Kittle-Kamp, William G. McGarrity, Kristyn A. Medina, Brian D. Netter, Phillip J. Taylor, and Allen Duane Webber, for petitioner.

Farhad Asghar, Kevin G. Croke, Anne O'Brien Hintermeister, Allan Lang, Aaron T. Vaughan, and Mary E. Wynne, for respondent.

OPINION

These consolidated cases are before the Court on the parties' cross-motions for partial summary judgment under Rule 121.1 The issue presented by the parties' cross-motions is whether section 1.482-7(d)(2), Income Tax Regs. (final rule) — which the Department of the Treasury (Treasury...

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