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District of Columbia Court of Appeals reverses summary judgment granted to oil companies in ‘Chainbridge’ litigation

The District of Columbia Court of Appeals on June 30 held that the Office of Administrative Hearings (OAH) abused its discretion in applying offensive nonmutual collateral estoppel against the District of Columbia Office of Tax and Revenue and granting summary judgment to three oil company taxpayers. The Court of Appeals remanded the case back to the OAH for reconsideration of whether offensive nonmutual collateral estoppel applied to these taxpayers, potentially setting up another substantive review of the Chainbridge methodology that has been used in addressing transfer pricing issues arising under the district’s corporation franchise tax.

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