In an article published in Insights in 2022, Michael Peggs commented that the Tax Court knew where it wanted to end up and simply looked for a method that was consistent with its destination. He predicted that the approach of the Tax Court was not likely to be upheld on appeal. In early September, the Tax Court’s decision was vacated and remanded for further proceedings. In the “boxing matches” taking place between (1) Medtronic and the I.R.S. and (2) the Tax Court and the Court of Appeals, it seems the boxers are in the fourth round of a ten-round bout. Stay tuned.