Eaton Redactions of Docs in IRS Audit Would Mire Case, US Argues

Eaton Corp. isn’t entitled to further redactions shielding information from its foreign employee records because those materials were already deemed relevant to a transfer pricing audit, the IRS told a federal court in Ohio.

The court “need not, and should not, run a fine-toothed comb through the evaluations to conduct a phrase-by-phrase comity balancing analysis that is more likely to multiply the disputed issues than it is to narrow them,” the US said in a briefMay 23.

The IRS is investigating Eaton for allegedly paying its Irish affiliate inflated royalties for intellectual property, thereby lowering the company’s US income ...