United States Tax Court October 28, 2019, 5576-12 (Eaton Corporation and Subsidiaries v. Commissioner)

153 T.C. No. 6

UNITED STATES TAX COURT

EATON CORPORATION AND SUBSIDIARIES, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent*

Docket No. 5576-12. Filed October 28, 2019.

P and R entered into two advance pricing agreements (APAs)

establishing a transfer pricing methodology for covered transactions

between P and its subsidiaries.