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John P. Warner, shareholder in Buchanan’s tax section, was quoted in a Bloomberg BNA article titled “IRS Arguments in ‘Guidant' Echo Losing Position in ‘Medtronic'.”

“Thus, the court in Medtronic did not purport to establish any point of law, but instead thought it was just applying established legal principles and rules to the facts at hand,” Warner said. “Furthermore, transfer pricing cases of this type are so factually driven that a Tax Court judge is not terribly hard-pressed to distinguish the facts in a given transfer price case from those in a case that was decided differently.”