Meta Fights $16 Billion Deficiency on Heels of Tax Court Ruling

Meta Platforms Inc. has brought a new petition accusing the IRS of incorrectly assessing $16 billion in tax deficiencies and related penalties for alleged errors resulting from international income sharing arrangements from 2017 to 2019.

The Facebook parent’s Dec. 4 petition alleges that the IRS’s periodic adjustments of its transfer of intangible property are arbitrary, capricious, or unreasonable. The tech giant argued that the IRS is barred from making periodic adjustments by collateral estoppel, estoppel, and res judicata under Rule 39.

The petition follows a May Tax Court ruling in a long-running dispute involving the tech giant’s valuation of ...