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Buchanan's John Warner, Shareholder in the Tax section, commented to Bloomberg Tax on Inc.'s recent court win over the IRS regarding cost-sharing arrangements.

“The court seems to be saying that such changes would have changed the outcome in Amazon, even though it isn’t setting precedent."

John's comments were also included in Law360's coverage of the same court decision, speculating that it might have implications for other cases involving interpretations from the IRS or other agencies.

"That 'fair warning' standard may be a hook that a lot of taxpayers use when challenging IRS actions — even outside the transfer pricing area — that are based on an expansive interpretation of an existing regulation," Warner said.