Jim Gadwood presented on administrative law challenges in tax controversies at the annual conference of the USA Branch of the International Fiscal Association. He addressed Altera Corp. v. Commissioner which held a transfer pricing regulation to be invalid. Gadwood noted that the court’s decision rests on the U.S. Department of the Treasury’s (Treasury's) insufficient evidence of alleged behavior between unrelated parties, which is usually not a consideration outside the transfer pricing context. For that reason, Gadwood said, "Altera on its face may not have broad applicability" except in situations where Treasury fails to respond to comments on proposed regulations.