Legal Opinion

Elec. Arts, Inc. v. Comm'r

United States Tax Court

Decided March 22, 2002No. 2433-99; No. 2434-99PublishedCited by 105 opinions

Before the years in issue, petitioner parent (EA) had relied on unrelated video games manufacturers in Taiwan and Japan to manufacture the video games that EA sold. EA created a subsidiary (EAPR) to move the video game manufacturing operations to Puerto Rico. EAPR entered into agreements with an unrelated company (PPI), which was located in Puerto Rico. PPI manufactured ignition modules and related products for small engines.

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Before the years in issue, petitioner parent (EA) had relied on unrelated video games manufacturers in Taiwan and Japan to manufacture the video games that EA sold. EA created a subsidiary (EAPR) to move the video game manufacturing operations to Puerto Rico. EAPR entered into agreements with an unrelated company (PPI), which was located in Puerto Rico. PPI manufactured ignition modules and related products for small engines. PPI did not own equipment, raw materials, or components to manufacture video games. Under the EAPR-PPI agreements, EAPR leased space in PPI's factory, leased employees…

1Opinion of the Court

OPINION

Chabot, Judge:

The instant cases are before us on petitioners’ motion under Rule 1211 for partial summary judgment that petitioner Electronic Arts Puerto Rico, Inc. (hereinafter sometimes referred to as eapr), is entitled to possessions tax credits under section 9362 for the years in issue computed using the “profit split method”.

Respondent determined deficiencies in corporate income tax against petitioner Electronic Arts, Inc. & Subsidiaries (hereinafter sometimes referred to as EA) and against petitioner EAPR, as follows:

Fiscal year1 EA EAPR

1993 $121,795 $1,977,045

1994 1,239,846…

2Cases cited49 opinions

  1. Anderson v. Liberty Lobby, Inc.Supreme Court of the United States · 1986
  2. Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
  3. Toyota Motor Manufacturing, Kentucky, Inc. v. WilliamsSupreme Court of the United States · 2002
  4. United States v. ButlerSupreme Court of the United States · 1936
  5. Associated Press v. United StatesSupreme Court of the United States · 1945

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3Cited by105 opinions

  1. Rauenhorst v. Comm'rUnited States Tax Court · 2002
  2. Cooper v. Comm'rUnited States Tax Court · 2011
  3. Robinson v. Comm'rUnited States Tax Court · 2002
  4. Fed. Home Loan Mortg. Corp. v. Comm'rUnited States Tax Court · 2003
  5. O'Donnabhain v. CommissionerUnited States Tax Court · 2010

100 more not listed; retrieve them via the Exa API.

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