Tax Court Judge Probes Averaging Pricing In Medtronic Trial

Law360 (June 23, 2021, 7:46 PM EDT) -- The U.S. Tax Court judge presiding over Medtronic's $1.36 billion transfer pricing trial asked Wednesday whether averaging the results of two rival pricing methods might yield the right figure, saying both seemed to possess their own deficiencies. 

Judge Kathleen Kerrigan asked an expert witness for the Internal Revenue Service, Iain Cockburn, professor at Boston University's Questrom School of Business, whether the court should average the comparable uncontrolled transaction method's result with that of the comparable profits method in order to determine the arm's-length royalty rate in the case. 

"Do you think [because] there are some attributes of the CUT and some...

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