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 …

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 …