The Seventh Circuit, in Wisconsin Big Boy, has recently indicated that arm's-length charges may not prevent a Section 482 reallocation among integrated multiple corporations. Mr. Lee analyzes this recent development and suggests that in the future the proper defense to a 482 attack may lie in a reasonable division of profits.
36 The Journal of Taxation 349-352 (1972)
Lee, John W., "CA-7's "Wisconsin Big Boy" Case Has Dire Implications in 482 Area" (1972). Faculty Publications. 1381.