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November 18, 2020

BREAKING TAX NEWS | Tax Court holds IRS did not abuse discretion in reallocating income under IRC Section 482 in transfer pricing case

Today, the U.S. Tax Court issued an opinion in The Coca-Cola Co. v. Commissioner, 155 T.C. No. 10 (2020). The court held that the Commissioner of Internal Revenue did not abuse his discretion under IRC Section 482 by reallocating income to Coca-Cola by employing the comparable profits method rather than the alternate transfer pricing methods submitted by the taxpayer.