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National Law Review
National Law Review
7/10/2026
The original headline is: "Government Drops Statute of Limitations Defense in McKesson Cost-Sharing Challenge"

The original headline is: "Government Drops Statute of Limitations Defense in McKesson Cost-Sharing Challenge"

Original: Government Drops Statute of Limitations Defense in McKesson Cost-Sharing Challenge

Short summary

The US government dropped its six-year statute of limitations defense in McKesson's challenge to Treasury stock-based compensation cost-sharing regulations under IRC §482. In its opposing brief, the government argued the regulations fall within broad statutory authority and cited Facebook v. Commissioner and Altera as supporting precedent. The merits of McKesson's regulatory challenge will now proceed without a timeliness barrier.

  • Government dropped six-year statute of limitations defense in McKesson cost-sharing case
  • Treasury argues IRC §482 regulations are within delegated authority and necessary for arm's-length results
  • Merits challenge to stock-based compensation cost-sharing rules will proceed on substantive grounds

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