Eli Lilly & Co. v. Commissioner

Procedural Posture Petitioner parent corporation and its subsidiary challenged respondent Commissioner of Internal Revenue’s
(IRS) ruling, which, pursuant to I.R.C. § 482, reallocated gross income from the subsidiary to the parent corporation.
The parent corporation alleged, in part, that the IRS erred in not attributing to the subsidiary the income from intangible property transferred from the parent corporation to the subsidiary pursuant to I.R.C. § 351.