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regulation, defines "intercompany transactions" and "deferred
intercompany transaction" as follows:
(a) Definitions.--For purposes of �� 1.1502-1 through
1.1502-80:
(1) "Intercompany transaction." (i) Except as
provided in subdivision (ii) of this subparagraph, the
term "intercompany transaction" means a transaction
during a consolidated return year [taxable year in
which the sale occurred] between corporations which are
members of the same [controlled] group immediately
after such transaction.* * *
* * * * * *
*
(2) "Deferred intercompany transaction".
The term "deferred intercompany transaction"
means--
(i) The sale or exchange of property,
* * * * * * *
in an intercompany transaction.
The 1984 temporary regulation provides that, except as
otherwise provided, "the rules for deferred intercompany
transactions in � 1.1502-13 of the consolidated return
regulations apply under section 267(f)(2)". 49 Fed. Reg. 46997
(Nov. 30, 1984). These words are intended to govern the
application of section 267(f). By this temporary regulation,
respondent has clarified and limited the operation of section
267(f)(2) to what are defined to be "intercompany transactions".
When the 1984 temporary regulation is read in light of the
definition of intercompany transactions in the consolidated
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