On 25 August 2022, the Sixth Circuit issued its decision in Eaton Corp. v. Commissioner, ruling in favor of Eaton Corporation.The Sixth Circuit held that the Internal Revenue Service (IRS) had the burden of proving that it had grounds to cancel the Advance Pricing Agreements (APAs) under contract-law principles and failed to do so.The Sixth Circuit ruled that the IRS forfeited its penalties claim by basing its post-trial claim on a new assessment.Executive summaryOn August 25, 2022, the United States (US) Sixth Circuit Court of Appeals (Sixth Circuit) held in Eaton Corp. & Subs. v. Commissioner1 that the IRS had the burden...