The Coca-Cola Company and Subsidiaries v. Commissioner

155 T.C. No. 10

UNITED STATES TAX COURT THE COCA-COLA COMPANY & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 31183-15. Filed November 18, 2020. P, a U.S. corporation, was the legal owner of the intellectual property (IP) necessary to manufacture, distribute, and sell some of the best-known beverage brands in the world. This IP included trade- marks, product names, logos, patents, secret formulas, and proprietary manufacturing processes. P licensed foreign manufacturing affiliates, called “supply points,” to use this IP to produce concentrate that they…