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Commission Commission
income per income as
FYE return Increase adjusted
6/30/89 $3,212,829 $3,120,433 $6,333,262
6/30/90 3,186,941 3,125,044 6,311,985
6/30/91 2,184,932 3,178,952 5,363,884
6/30/92 1,511,017 3,179,676 4,690,693
Respondent calculated the increased commission on the basis of
petitioner's operating costs plus 54 percent of those costs.
OPINION
In General
Section 48215 gives the Commissioner broad authority to
allocate income, deductions, credits, or allowances between
15Sec. 482 provides:
In any case of two or more organizations,
trades, or businesses (whether or not
incorporated, whether or not organized in the
United States, and whether or not affiliated)
owned or controlled directly or indirectly by the
same interests, the Secretary may distribute,
apportion, or allocate gross income, deductions,
credits, or allowances between or among such
organizations, trades, or businesses, if he
determines that such distribution, apportionment,
or allocation is necessary in order to prevent
evasion of taxes or clearly to reflect the income
of any of such organizations, trades, or
businesses. In the case of any transfer (or
license) of intangible property (within the
meaning of section 936(h)(3)(B)), the income with
respect to such transfer or license shall be
commensurate with the income attributable to the
intangible.
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