Summary: In this 346-page opinion (including multiple concurring opinions and dissents) the Tax Court addresses federal income tax issues arising from 3M Company (3M) and its domestic and foreign subsidiaries’ (Subs)...more
3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more