Seagate Technology v. Commissioner
United States Tax Court
P, a corporation whose stock is publicly traded, is a leading manufacturer of hard disk drives for personal computers. During its fiscal year ended 1983, P organized S as a wholly owned subsidiary to manufacture component parts in Singapore for use by P in the manufacture of hard disk drives in the United States. During its fiscal year ended 1984, P expanded S's operations to include the manufacture of completed disk drives in Singapore.
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P, a corporation whose stock is publicly traded, is a leading manufacturer of hard disk drives for personal computers. During its fiscal year ended 1983, P organized S as a wholly owned subsidiary to manufacture component parts in Singapore for use by P in the manufacture of hard disk drives in the United States. During its fiscal year ended 1984, P expanded S's operations to include the manufacture of completed disk drives in Singapore. P contributed to S's capital certain intangibles for use in the manufacture of the completed disk drives. P purchases component parts from S for use in disk…
1Opinion of the Court
CONTENTS
Page
156 STATEMENT OF ISSUES .
157 I. GENERAL FINDINGS OF FACT
A. Background in General . ÜI <1
B. The Industry in General . ÜT CO
C. Seagate Scotts Valley. a lO t-H
D. Seagate Singapore. o CD tH
161 II. ISSUE 1: WHETHER RESPONDENT’S REALLOCATIONS OF GROSS INCOME UNDER SECTION 482 ARE ARBITRARY, CAPRICIOUS, AND UNREASONABLE.
161 A. FINDINGS OF FACT .
161 1. The Notices of Deficiency.
162 2. Respondent’s Expert Reports .
163 B. OPINION .
163 1. The Parties’ Positions .
163 2. Section 482 in General.
165 III. ISSUE 2: WHETHER RESPONDENT SHOULD BEAR THE BURDEN OF PROOF FOR ANY OF THE ISSUES INVOLVED…
2Cases cited22 opinions
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993
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- Parker v. CommissionerUnited States Tax Court · 1986
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