Altera Corp. v. Cir

FOR PUBLICATION UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT ALTERA CORPORATION & Nos. 16-70496 SUBSIDIARIES, 16-70497 Petitioner-Appellee, Tax Ct. Nos. v. 6253-12 9963-12 COMMISSIONER OF INTERNAL REVENUE, OPINION Respondent-Appellant. Appeal from a Decision of the United States Tax Court Argued and Submitted October 11, 2017 San Francisco, California Filed July 24, 2018 Before: Sidney R. Thomas, Chief Judge, and Stephen Reinhardt* and Kathleen M. O’Malley** Circuit Judges. Opinion by Chief Judge Thomas; Dissent by Judge O’Malley * Judge Reinhardt fully participated in this case and…