Legal Opinion
Eaton Corporation and Subsidiaries v. Commissioner
United States Tax Court
Decided October 28, 2019No. 5576-12Unknown
1Opinion of the Court
153 T.C. No. 6
UNITED STATES TAX COURT EATON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket No. 5576-12. Filed October 28, 2019. P and R entered into two advance pricing agreements (APAs) establishing a transfer pricing methodology for covered transactions between P and its subsidiaries. Following our previous opinion holding that R’s determination to cancel the APAs for tax years 2005 and 2006 was an abuse of discretion, the parties were required to submit computations for entry of decision under Tax Court Rule 155. The parties have not…
2Cases cited10 opinions
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- National Life Insurance v. United StatesSupreme Court of the United States · 1928
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1991
- Eli Lilly & Company and Subsidiaries, Cross-Appellees v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Seventh Circuit · 1988
- Home Group v. CommissionerUnited States Tax Court · 1988
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