The Tax Court’s new opinion deciding the blocked income question raised in Coca-Cola v. Commissioner, T.C. Memo. 2023-135, suggests that Coca-Cola’s prospects of eventual success are dim, whether the blocked income regulations are upheld on appeal or not.
Judge Albert Lauber’s November 8 supplemental opinion in Coca-Cola is the epilogue to the landmark 2020 opinion (155 T.C. 145 (2020)) that handed the IRS a decisive victory in a case concerning transfer pricing method selection.
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