Inverworld, Inc., et al. - Page 150

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            of tax liability by court action.  A correlative adjustment is                                
            not required to be made until a primary adjustment is made.  Sec.                             
            1.482-1(d)(2), Income Tax Regs.  As the primary adjustment is not                             
            considered to have been made until a final determination of tax                               
            liability by court action, a correlative adjustment is also not                               
            required to be made until that time.  Accordingly, as a final                                 
            determination of tax liability by court action will not occur                                 
            until after the issuance of this opinion, the correlative                                     
            adjustment is not required to be made until after issuance of                                 
            this opinion.  The record, however, contains all facts necessary                              
            to decide, at this point, whether LTD is entitled to a                                        
            correlative adjustment.                                                                       
                  Petitioners contend that "As a matter of law, if not simple                             
            logic, should the * * * [Tax] Court reallocate any amount of                                  
            LTD’s income to INC, then LTD’s taxable income should be reduced                              
            in equal amount."  Petitioners cite the correlative adjustment                                
            provisions of section 1.482-1(d)(2), Income Tax Regs., as support                             
            for the treatment of any section 482 allocation of income to INC                              
            as a deduction to LTD.  Petitioners note that denying the                                     
            deduction of the section 482 correlative adjustment to LTD                                    
            results in taxing the same dollar twice:  once in the hands of                                
            LTD and once in the hands of INC.                                                             
                  Respondent agrees that LTD would ordinarily be entitled to a                            
            correlative adjustment equal to the primary adjustment to INC.                                
            Respondent notes, however, that deductions are a matter of                                    
            legislative grace and not a matter of right.  Gladstone Co. v.                                




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