Inverworld, Inc., et al. - Page 35

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          member would not be affected for any pending taxable year and the           
          correlative adjustment is therefore not actually made, "such                
          adjustment shall nevertheless be deemed to have been made" for              
          purposes of determining the other member's U.S. income tax                  
          liability for a later taxable year or for purposes of determining           
          any other person's U.S. income tax liability for any taxable                
          year.  Id.                                                                  
               Accordingly, the regulations provide that an appropriate               
          correlative adjustment, if one is made by the district director,            
          either "shall actually be made" or "shall nevertheless be deemed            
          to have been made".  Id.  In that context, the phrase, "The                 
          correlative adjustment shall actually be made", is merely a                 
          description of the result that occurs when the district director            
          makes an appropriate correlative adjustment and the U.S. income             
          tax liability of the other member would be affected for any                 
          pending taxable year, as opposed to a correlative adjustment that           
          is deemed to have been made.  The phrase "shall actually be                 
          made", therefore, does not mandate that a correlative adjustment            
          always be made but, rather, serves only to describe one of the              
          two alternative ways of treating an appropriate correlative                 
          adjustment, if one is made by the district director.                        
               Accordingly, we note that the language, "Thus, if the                  
          district director makes an allocation of income, he shall not               
          only increase the income of one member of the group, but shall              
          decrease the income of the other member", appears in the sentence           




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