As noted in its 22 June 2020 Order List, the U.S. Supreme Court has declined to issue a writ of certiorari in the case Altera Corp. v. Commissioner of Internal Revenue. As such, the decision issued by the U.S. Court of Appeals for the Ninth Circuit in June 2019 is the final decision in the case ({News-2019-06-11/A/5-previous coverage}).

The June 2019 decision concerns whether regulation 26 C…