The IRS, in a tax case against Amazon.com Inc. that could lead to an additional pay-up of $1.5 billion in taxes, is “desperately fighting” to get an appeals court to overturn the U.S. Tax Court’s company-favorable decision.
Attorneys for the Internal Revenue Service and Amazon stood before a three-judge panel April 12 in the U.S. Court of Appeals for the Ninth Circuit in Seattle to defend their positions in their second face-off over the value of intangible property—like patents and trademarks—that the online retailer transferred to its unit in Luxembourg in 2005.
“This case presents a problem that ...