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Eaton A.P.A. Cancellations Were an Abuse of I.R.S. Discretion

Volume 4 No 9    /    Read Article

By Michael Peggs

A recent U.S. Tax Court decision involving Eaton Corporation affirmed that the I.R.S. cannot arbitrarily circumvent administrative rules that are set down in revenue procedures and relied upon by the I.R.S. and a taxpayer. As a result, the I.R.S. must reasonably exercise its discretion when seeking to terminate an advance pricing agreement with a taxpayer. Michael Peggs looks at the process of obtaining an advanced pricing agreement and comments on the court’s decision.    See more →