Page "Transfer pricing" Paragraph 88
from
Wikipedia
Where prices charged are outside that range, prices may be adjusted by the IRS unilaterally to the midpoint of the range.
The burden of proof that a transfer pricing adjustment by the IRS is incorrect is on the taxpayer unless the IRS adjustment is shown to be arbitrary and capricious.
However, the courts have generally required that both taxpayers and the IRS to demonstrate their facts where agreement is not reached.
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