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regulations provide a guide to identifying the "true taxable
income" of each entity on the basis of the taxable income that
would have resulted had the entities been uncontrolled parties
dealing at arm's length. See Sundstrand Corp. & Subs. v.
Commissioner, supra at 353; sec. 1.482-1(b)(1), Income Tax Regs.
The Commissioner's determination as set forth in the notice of
deficiency is presumptively correct. The taxpayer has the burden
of disproving that determination. Rule 142(a); Welch v. Helvering,
290 U.S. 111 (1933). In meeting its burden, the taxpayer must
prove that it did not improperly utilize its control to shift
income. Procter & Gamble Co. v. Commissioner, 95 T.C. 323, 331
(1990), affd. 961 F.2d 1255 (6th Cir. 1992). Furthermore, where the
Commissioner determines that an allocation under section 482 is
necessary to prevent either tax evasion or the distortion of a
taxpayer's income, the determination must stand unless the taxpayer
proves that the determination is unreasonable, arbitrary, or
capricious. Ballentine Motor Co. v. Commissioner, 321 F.2d 796, 800
(4th Cir. 1963), affg. 39 T.C. 348 (1962); Seagate Tech., Inc. &
Consol. Subs. v. Commissioner, supra at 164; Sundstrand Corp. &
Subs. v. Commissioner, supra at 353. Absent a showing of abuse of
discretion, the Commissioner's section 482 determination must be
sustained. Sundstrand Corp. & Subs. v. Commissioner, supra; Bausch
& Lomb, Inc. & Consol. Subs. v. Commissioner, 92 T.C. 525, 582
(1989), affd. 933 F.2d 1084 (2d Cir. 1991). "Whether respondent
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