EATON CORP. & SUBS. v. COMMISSIONER

Docket No. 5576-12.

140 T.C. 410 (2013)

140 T.C. No. 18

EATON CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed June 26, 2013.



OPINION

KROUPA, Judge:

This matter is before the Court on cross-motions for partial summary judgment under Rule 121.1 The parties agree on the basic facts necessary to resolve a discrete issue of law. Petitioner and respondent entered into two advance pricing agreements (APAs) that set a transfer pricing methodology for certain transactions under section 482 (APAs at issue). Respondent...

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