The IRS overstepped its authority when it increased
The US Court of Appeals for the Eighth Circuit reversed the IRS’s victory, holding that allocation powers Congress granted the agency under IRC Section 482don’t support the agency’s actions in the case, nor can the IRS preempt the statute with the Treasury’s “blocked income” rule, 26 CFR Section 1.482-1(h)(2).
3M appealed the US Tax Court’s plurality ruling that the IRS ...
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