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USAco is the wholly-owned U.S. subsidiary of ASIAco, a Japanese parent corporation that manufactures automobiles and sells them to USAco for resale in the United States. ASIAco sells the automobiles to USAco for $20,000 and USAco resells the automobiles for $21,000. After a lengthy transfer pricing examination, the IRS proposes an adjustment, based on what it believes is the arm's length price that ASIAco should charge USAco of $17,000 per automobile. USAco would like to file a protest at Appeals, but is also considering seeking relief from the U.S. competent authority. What are USAco's options? Explain.
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