Respondent determined the following deficiency in petitioners’ Federal income tax for 1982: Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue. All Rule references are to the Tax Court …
Apple Computer, Inc. v. Comm’r, 98 T.C. 232 (1992)
Respondent determined deficiencies in the consolidated income tax of Apple Computer, Inc. and Consolidated Subsidiaries for their 1981, 1982, and 1983 fiscal years. The parties filed cross-motions for partial summary judgment pursuant to Rule 121. [1] Summary judgment is appropriate …