Eaton Corporation and Subsidiaries v. Commissioner

140 T.C. No. 18

UNITED STATES TAX COURT EATON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5576-12. Filed June 26, 2013. P and R entered into two advance pricing agreements (APAs) establishing a transfer pricing methodology for covered transactions between P and its subsidiaries. P and R agreed in the APAs that the APAs’ legal effect and administration were governed by certain revenue procedures. R determined P did not comply with the applicable terms and canceled the APAs. R issued P a deficiency notice and applied an alternative transfer…