[d] The aquot;Fourthaquot; Method The fourth method is not a method at all but rather a hodgepodge of techniques used by the Service. ... of the fourth method adds even more leeway to the Secretarya#39;s broad discretion in transfer pricing cases and increases a taxpayera#39;s difficulty in resisting intercompany pricing reallocations. ... 21 EI DuPont de Nemours and Co v US, 608 F2d 445 (Ct CI 1979). 22 aquot;Audit Techniques a International Enforcement Program, aquot; IRS Audit Manual Ch 500 , at As 523 . 2 .
|Title||:||Proceedings of New York University ... Annual Institute on Federal Taxation|
|Author||:||New York University. Institute on Federal Taxation|