Kristina Novak, Andrew Roberson and Kevin Spencer wrote this bylined article on a Tax Court dispute between Coca-Cola and the IRS over a closing agreement for transfer pricing adjustments. “The IRS is fighting what seems to be a losing battle” over “clearly questionable motions,” the authors wrote, adding that “our advice to clients is to look at the big picture strategy and do not get mired into petty squabbles with opposing counsel.”