ALJ Rejects Collateral Estoppel in D.C. Transfer


Stephen Kranz said that, although an administrative law judge upheld use of the Chainbridge transfer pricing analysis which was previously rejected in the District of Columbia Microsoft decision, “we remain convinced that the Chainbridge method assessments should be invalidated based on the reasoning in the Microsoft case. Taxpayers facing these transfer pricing assessments should continue to file suits challenging application of this faulty method.”