277 F.3d 778 (5th Cir. 2001) COMPAQ COMPUTER CORPORATION AND SUBSIDIARIES, Petitioner-Appellant,v.COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 00-60648 UNITED STATES COURT OF APPEALSFIFTH CIRCUIT December 28, 2001 Appeal from the Decision of the United States Tax Court Before JONES, SMITH, and DeMOSS, Circuit Judges. EDITH H. JONES, Circuit Judge: 1 In this case, Compaq Computer […]