Coca-Cola Disputes IRS’s Logic Behind $3 Billion Tax Bill (1)

Coca-Cola Co. is fighting back against a U.S. Tax Court ruling that left the company on the hook for most of a more-than $3 billion tax bill, arguing the IRS broke the law when calculating the amount.

The unprecedented nature of a November opinion upholding IRS adjustments to the company’s tax bill warrants further consideration, potentially by the full Tax Court, Coca-Cola said in a motion for reconsideration that was obtained by Bloomberg Law.

The case is one of the most high-profile IRS disputes involving transfer pricing, the way companies price transactions between their subsidiaries. The Coca-Cola ...