Medtronic, Inc. v. Commissioner, T.C. Memo. 2022-84 (2022). One of the most significant Section 482 transfer pricing disputes ever litigated in the Tax Court. The case involved a second trial in the U.S. Tax Court following the Eighth Circuit’s review and remand. The court’s 2022 opinion adopted Medtronic’s transfer pricing methodology but made certain adjustments in favor of the IRS.
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