- 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.Page: Previous 193 194 195 196 197 198 199 200 201 202 203 204 205 206 207 208 209 210 211 212 Next
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