Inverworld, Inc., et al. - Page 32

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          adjustments are necessary to avoid multiple taxation of the same            
          income.                                                                     
               Petitioners' argument that the regulations provide for a               
          correlative adjustment "in all circumstances" is without merit.             
          Section 1.482-1(d)(2), Income Tax Regs., provides that the                  
          district director, whenever making primary adjustments, "shall              
          also make appropriate correlative adjustments".  (Emphasis                  
          added.)  We believe that the term "appropriate" serves to limit             
          the application of a correlative adjustment so that a correlative           
          adjustment is not made "in all circumstances", but, rather, only            
          when "appropriate".  Sec. 1.482-1(d)(2), Income Tax Regs.                   
          Additionally, section 1.482-1(d)(1), Income Tax Regs., which                
          addresses all section 482 adjustments (as opposed to section                
          1.482-1(d)(2), Income Tax Regs., which addresses only primary and           
          correlative adjustments), requires that all adjustments be                  
          "appropriate".14                                                            

          14   Section 1.482-1(d)(1), Income Tax Regs., provides:                     
                    The method of allocating, apportioning, or                        
               distributing income, deductions, credits, and                          
               allowances to be used by the district director in any                  
               case, including the form of the adjustments and the                    
               character and source of amounts allocated, shall be                    
               determined with reference to the substance of the                      
               particular transactions or arrangements which result in                
               the avoidance of taxes or the failure to clearly                       
               reflect income.  The appropriate adjustments may take                  
               the form of an increase or decrease in gross income,                   
               increase or decrease in deductions (including                          
               depreciation), increase or decrease in basis of assets                 
               (including inventory), or any other adjustment which                   
                                                             (continued...)           




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