Inverworld, Inc., et al. - Page 36

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          immediately after the one providing the conditions under which a            
          correlative adjustment "shall actually be made".  In that                   
          context, the language merely describes the steps to be taken when           
          an appropriate correlative adjustment is "actually" being made.             
          Accordingly, we conclude that the phrase "shall decrease the                
          income of the other member" only applies when the district                  
          director, after deciding that a correlative adjustment is                   
          appropriate under the circumstances, "actually" makes the                   
          correlative adjustment; such language does not mandate that the             
          district director, when increasing the income of one member of              
          the group, must always decrease the income of the other member.             
               As we held supra and in our prior opinion that LTD is not              
          entitled to deduct the section 482 allocations of income to INC             
          as additional compensation expenses because LTD failed to file              
          timely, true, and accurate returns pursuant to section 882(c)(2),           
          we conclude that correlative adjustments are not appropriate                
          under the circumstances of the instant case.                                
               In our prior opinion, we addressed petitioners' argument               
          regarding double taxation and distinguished Collins Elec. Co. v.            
          Commissioner, 67 T.C. 911 (1977).  Accordingly, we do not                   
          reconsider our holding that LTD is not entitled to correlative              
          adjustments pursuant to section 1.482-1(d)(2), Income Tax Regs.,            
          for the taxable years in issue.                                             








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