3. The IRS is conducting a transfer pricing examination of USAco, a wholly-owned U.S. subsidiary...
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3. The IRS is conducting a transfer pricing examination of USAco, a wholly-owned U.S. subsidiary of FORco. USAco purchases widgets from FORco for resale in the United States. The IRS examines USAcos transfer pricing practices for a year in which the statute of limitations will expire in six months. With respect to FORcos manufacturing costs, USAco has failed to reply to information document requests and a summons that is currently docketed in court for enforcement. What procedural tools may the IRS employ to obtain information regarding FORcos manufacturing costs? Explain
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