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Altera Corp. v. Commissioner of Internal Revenue

Ruling by

Sidney R. Thomas

Lower Court

Tax Court

dissenting Judge(s)

Kathleen O'Malley
Treasury Regulation Section 1.482-7(d)(2) was not invalid under 'Chevron' or 'State Farm' statutory interpretation schemes, as it was not arbitrary and capricious and complied with Administrative Procedure Act's procedural requirements.



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