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IRS Victory: 3M Transfer Pricing Challenge Update

Tax Notes Talk

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UC Irvine Graduate Tax Program - The University of California Irvine School of Law

The commensurate with income standard was the focus of two concurrences written by judges Kathleen Carrigan and Elizabeth Copeland. In another dissent, Judge Kerry Pugh argued that this first security bank opinion rested in general, and therefore that no amendment to Section 482 could overturn it. UCI's Graduate Tax Program helps prepare students for a future in tax law.

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