- 35 - 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 sentencePage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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