Overview
Stephen Kranz, M. Miller Baker and Diann Smith represent three major oil companies in an administrative judge’s hearing of their complaint about third-party transfer pricing software used by the DC Office of Tax and Revenue to assess tax liabilities against the companies. The software is “not scientific, it’s not fact-based” argued Mr. Kranz, noting “there was no analysis of the taxpayer’s books and records. There was no audit in the traditional sense.”