Eaton Corp. v. Comm'r
United States Tax Court
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 pricing methodology. P filed a petition.
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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 pricing methodology. P filed a petition. P contends the APAs are enforceable contracts. P asserts R must show that he was entitled to cancel the APAs. R asserts he canceled…
1Opinion of the Court
EATON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Eaton Corp. v. Comm'r
Docket No. 5576-12.
United States Tax Court
140 T.C. 410; 2013 U.S. Tax Ct. LEXIS 19; 140 T.C. No. 18;
June 26, 2013, Filed
An appropriate order will be issued.
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…
2Cases cited19 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Naftel v. CommissionerUnited States Tax Court · 1985
- Greenberg's Express, Inc. v. CommissionerUnited States Tax Court · 1974
- Mailman v. CommissionerUnited States Tax Court · 1988
- Commissioner v. EngleSupreme Court of the United States · 1984
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