IRS Victory: 3M Transfer Pricing Challenge Update
Tax Notes Talk
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How Did the Majority Come Out?
The main issue was whether 3M actually satisfied these regulations, you know, was in most cases stipulated. There's the sort of substantive validity under Chevron and the procedural validity under the administrative procedure act. The question is really whether a 1972 Supreme Court decision, first security bank of Utah v. Commissioner, was controlling precedent for this case.
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