Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / formal-protest-redline-v2-to-v3.docx
formal-protest-redline-v2-to-v3.docx
Parties
Penterra Pharmaceuticals Corp
Harkness LLP
PRELIMINARY STATEMENT Penterra Pharmaceuticals Corp
Penterra Manufacturing Ireland Ltd
Associates LLP
See Harborview Corp
See Altera Corp
Whitmore Valuation Group LLC
Dates
October 12, 2023
November 8, 2023
June 8, 2022
December 31, 2017
December 31, 2018
December 31, 2019
December 31, 2020
March 15, 2012
July 1, 2012
May 16, 2022
Amounts
$6.82
$380,400,000
$235,010,000
$188,040,000
$42,650,000
$312,000,000
$3.12
$1.34
$1.87
$0.79
Obligations
482-1(c), which provides that the arm's-length result of a controlled transaction must be determined under the method that "provides the most reliable measure of an arm's length result
Where the taxpayer's method is reasonable and its results fall within the arm's-length range, the IRS's proposed reallocation must be rejected