Electronic Arts, Inc. and Subsidiaries v. Commissioner

118 T.C. No. 13

UNITED STATES TAX COURT ELECTRONIC ARTS, INC. AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ELECTRONIC ARTS PUERTO RICO, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 2433-99, 2434-99. Filed March 22, 2002. 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…