Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / letter-to-irs-protest-extension-20231115.docx
letter-to-irs-protest-extension-20231115.docx
Parties
HARKNESS LLP
Penterra Pharmaceuticals Corp
Whitmore Valuation Group LLC
Associates LLP
Dates
November 15, 2023
June 8, 2022
November 8, 2023
December 8, 2023
December 22, 2023
May 16, 2022
December 31, 2017
December 31, 2018
December 31, 2019
December 31, 2020
Amounts
$380,400,000
$235,010,000
$188,040,000
$42,650,000
$15,977,000
$380.4
€47.2
$814.6
$624.1
Obligations
Specifically, the Protest must address the following substantive issues, among others: (1) Valuation of the Platform Contribution Transaction
482-4, and must present PPC's comparable license agreement analysis in support of the 4
The Protest must address and incorporate the results of economic analyses that draw upon this extensive factual record
Each of these economic analyses involves multiple layers of data, assumptions, and sensitivity analyses that must be carefully presented and explained in the Protest to ensure that the Office of Appeals has a clear and complete understanding of PPC's positions
Multiple Tax Years and Distinct Issues Across Years The Protest must address distinct legal and factual arguments applicable to each of the four tax years under examination
The Protest must address the year-specific factual bases for PPC's reported percentages and the methodological errors in the IRS's proposed revisions