In Guidant Corp v. Commissioner, the US Tax Court today denied the taxpayers’ motion for partial summary judgment, holding that the IRS acted within its authority to make the transfer pricing adjustments at issue.  Taxpayers, members of a consolidated group, conducted through US subsidiaries various transactions with foreign affiliates including licensing of intangibles, the purchase and sale of manufactured property, and services.  The IRS, relying on section 482, made adjustments to the prices reported in the transactions.  The taxpayers challenged these adjustments on the grounds that the IRS did not determine the separate taxable income (STI) of each controlled taxpayer and that the IRS did not make specific adjustments with respect to each transaction.  The Tax Court held that IRC section 482 does not require the IRS to determine the STI of each controlled taxpayer in a consolidated group.  The Tax Court further held that section 482 allows the IRS to aggregate related transactions instead of making specific adjustments with respect to each type of transaction.