Pepsico P.R., Inc. v. Commissioner

1 Analyses of this case by attorneys

  1. Legal Alert: The 2013 Tax Litigation Year in Review: Important Events

    Sutherland Asbill & Brennan LLPJanuary 31, 2014

    In contrast, where cases involve straightforward business transactions, e.g., genuine debt instruments, the U.S. Tax Court has shown that it is generally favorable towards taxpayers. SeeNA General Partnership & Subsidiaries v. Commissioner, 103 T.C.M. (CCH) 1916 (2012) (ScottishPower); PepsiCo Puerto Rico, Inc. v. Commissioner, 104 T.C.M. (CCH) 322 (2012). For a more detailed analysis of these opinions, click here.The LILO/SILO Transactions –ConEdison,UnionBanCal and John Hancock Opinions issued by the Federal Circuit, Court of Federal Claims and Tax Court in 2013 mark the final group of opinions concerning LILO/SILO transaction cases.