Virginia Law Review, Svazek 57,Díl 2Virginia Law Review Association., 1971 |
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Strana 1414
... allocation under sec- tion 482 , but rather would sanction such an allocation wherever there is common control.189 Although the courts initially refused to allow the Commissioner to allocate income among entities not under common ...
... allocation under sec- tion 482 , but rather would sanction such an allocation wherever there is common control.189 Although the courts initially refused to allow the Commissioner to allocate income among entities not under common ...
Strana 1431
... allocation.266 Utilization of an allocation formula and a functional test would obviate some of the difficulties in the present benefit test in determining to which tax- payer a deduction is attributable . Management services , whether ...
... allocation.266 Utilization of an allocation formula and a functional test would obviate some of the difficulties in the present benefit test in determining to which tax- payer a deduction is attributable . Management services , whether ...
Strana 1432
... allocation was unreasonable , arbitrary , and capricious . Accordingly , they argued the Commissioner had failed to prove in the Tax Court any less extreme allocation , and no allocation should be allowed . The Commissioner countered ...
... allocation was unreasonable , arbitrary , and capricious . Accordingly , they argued the Commissioner had failed to prove in the Tax Court any less extreme allocation , and no allocation should be allowed . The Commissioner countered ...
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