Inverworld, Inc., et al. - Page 124

                                                - 203 -                                                   
            deciding whether the Commissioner's determination is reasonable,                              
            courts focus on the reasonableness of the result, not on the                                  
            details of the methodology used.  Bausch & Lomb, Inc. v.                                      
            Commissioner, supra at 582; see also Eli Lilly & Co. v. United                                
            States, 178 Ct. Cl. 666, 676, 372 F.2d 990, 997 (1967).                                       
                  Once the taxpayer has proved that the deficiencies set forth                            
            in the notice of deficiency are arbitrary, capricious, or                                     
            unreasonable, the taxpayer has the additional burden of proving                               
            satisfaction of the arm's length standard.  See Eli Lilly & Co.                               
            v. Commissioner, 856 F.2d at 860; Sundstrand Corp. v.                                         
            Commissioner, supra at 354.                                                                   
                  In the instant case, as between LTD and INC, respondent's                               
            allocations at least must be reasonable attempts to reflect arm's                             
            length transactions.  See Achiro v. Commissioner, 77 T.C. 881,                                
            900 (1981).                                                                                   
                        b.     The Section 482 Regulations                                                
                  The term "controlled" is defined as including "any kind of                              
            control, direct or indirect, whether legally enforceable, and                                 
            however exercisable or exercised."  Sec. 1.482-1(a)(3), Income                                
            Tax Regs.  The term "controlled taxpayer" means "any one of two                               
            or more organizations, trades, or businesses owned or controlled                              
            directly or indirectly by the same interests."  Sec. 1.482-                                   
            1(a)(4), Income Tax Regs.  The terms "group" and "group of                                    
            controlled taxpayers" mean "the organizations, trades, or                                     
            businesses owned or controlled by the same interests."  Sec.                                  





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