Government appeals Tax Court’s decision, section 482 | KPMG | GLOBAL
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United States: Government appeals Tax Court’s decision, section 482 adjustment

Government appeals Tax Court’s decision, section 482

The U.S. government has filed a notice of appeal with the U.S. Tax Court, appealing that court’s decision in a 2016 case in which the court found that the IRS's section 482 adjustments of $548 million for 2005 and $810 million for 2006 were “arbitrary, capricious, and unreasonable.”


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The appeal in Medtronic Inc. v. Commissioner, T.C. Memo. 2016-112, is to the U.S. Court of Appeals for the Eighth Circuit. Read text and a brief description of the Tax Court case in TaxNewsFlash-Transfer Pricing.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services team in the United States:

Mark Horowitz | +1 (713) 319-2840 |

Mark Martin | +1 (713) 319-2000 |

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