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Section 267(b) enumerates certain relationships. Most of
the relationships enumerated are intrafamily or equivalent
relationships where there is a unity of economic interest. The
section also provides that members of a controlled group as
defined in subsection (f) are among the enumerated relationships.
Section 267(d) provides, in general terms, that if a loss has
been disallowed under section 267(a)(1) only so much of the gain
on the subsequent resale of the property as exceeds the loss is
recognized by the related party purchaser. However, section
267(f)(2) requires different treatment for sales between members
of a controlled group. Section 267(f) provides in relevant part:
(f) Controlled Group Defined; Special Rules Applicable to
Controlled Groups.--
(1) Controlled group defined.--For purposes of this
section, the term "controlled group" has the meaning given
to such term by section 1563(a), except that--
(A) "more than 50 percent" shall be substituted
for "at least 80 percent" each place it appears in
section 1563(a), and
(B) the determination shall be made without regard
to subsections (a)(4) and (e)(3)(C) of section 1563.
(2) Deferral (rather than denial) of loss from sale or
exchange between members.--In the case of any loss from the
sale or exchange of property which is between members of the
same controlled group and to which subsection (a)(1) applies
(determined without regard to this paragraph but with regard
to paragraph (3))--
(A) subsections (a)(1) and (d) shall not
apply to such loss, but
(B) such loss shall be deferred until the property
is transferred outside such controlled group and there
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