...credits, or allowances between or among such organizations, trades, or businesses, if it is determined that such distribution, apportionment, or allocation...any of such organizations, trades, or businesses. Section 1. 482-2 (c) (1) of the regulations provides, in part, that where possession, use, or occupancy...

...credits, or allowances between or among such organizations. • * * If he determines that such • » • allocation is necessary in order to prevent evasion...any of such organizations, trades, or businesses. The goal of this "statutory allocation procedure is to insure that controlled taxpayers are placed...

...organizations, trades, or businesses owned or controlled directly or indirectly by the same interests, in order to prevent evasion of taxes or clearly to...any of such organizations, trades, or businesses. In the instant case section 267 of the Code cannot apply to disallow the loss because the relationship...

...parent could lay claim, dispose, as we have said, of any possible argument that respondent's action is necessary in order "to prevent evasion of taxes...reflect the income of any of such organizations." Rodney, Inc., 2 TC 1020; affd. (CCA, 2d Cir.), 145 Fed. (2d) 692, is not to the contrary. That case...

...his delegate may distribute, apportion, or allocate gross income, deductions, credits or allowances between or among such organizations, trades, or businesses,...any of such organizations, trades, or businesses. Petitioner takes the position that the allocation of additional rent to him is improper because (1)...

...his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses,...any of such organizations, trades, or businesses. affd. 321 F.2d 796 (4th Cir. 1963). We think respondent properly may do so in this instance. One of...

...his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses....any of such organizations, trades, or businesses. The purpose of section 482, as interpreted by the respondent, is set forth in section 1.482-l(b) (1)...

...his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses,...evasion of taxes or clearly to reflect the income of any such organizations, trades, or businesses. 4 Bittker & Eustice, Federal Income Taxation of Corporations...

...his delegate may distribute, apportion, or allocate gross Income, deductions, credits, or allowances between or among such organizations, trades, or businesses....evasion of taxes or clearly to reflect the income oí any of such organizations, trades, or businesses. [T£>. 6595, 27 FR 3597, Apr. 14, 1962] § 1.482—1...

...apportion, or allocate gross income, deductions, credits, or allowances" between related organizations "if he determines that such distribution, apportionment,...reflect the income of any of such organizations." Nothing in this language limits the authorization to situations in which the nonarm's-length transaction...