Today, the US Tax Court issued a memorandum opinion in Medtronic Inc. v. Commissioner, holding in favor of Medtronic in a major transfer pricing decision that involved more than $1 billion in assessed deficiencies. The Tax Court held, in part, that the IRS did not give “appropriate weight” to the role of Medtronics’ Puerto Rico affiliate and that Medtronic had met its burden of showing that the IRS’s allocations were arbitrary, capricious, or unreasonable.