Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / protest-exhibit-e-penalty-protection.docx
protest-exhibit-e-penalty-protection.docx
Parties
Harkness LLP
Penterra Pharmaceuticals Corp
Associates LLP
Whitmore Valuation Group LLC
Harborview Corp
Penterra Manufacturing Ireland Ltd
Ireland Inc
Dates
December 22, 2023
October 6, 2023
August 1, 2022
July 1, 2012
December 31, 2017
December 31, 2018
December 31, 2019
December 31, 2020
June 2, 2022
June 20, 2022
Amounts
$380,400,000
$15,977,000
$5,000,000
$6,820,000,000
$312,000,000
$487,300,000
$523,800,000
$561,200,000
$598,400,000
$186,150,000
Obligations
The documentation must be maintained for each taxable year in which the taxpayer has controlled transactions subject to section 482
The regulations prescribe specific categories of information that must be included in the taxpayer's contemporaneous documentation
The taxpayer need not demonstrate that its position is more likely than not correct; rather, it must demonstrate that its position reflects a genuine, good-faith effort to comply with the arm's-length standard