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commonly controlled organizations, trades, or businesses if the
Commissioner determines that the allocation is necessary to
prevent the evasion of taxes or clearly to reflect the income of
the controlled entities. The purpose of section 482 is to
prevent the artificial shifting of the net incomes of controlled
taxpayers by placing controlled taxpayers on a parity with
uncontrolled, unrelated taxpayers. See Seagate Tech., Inc. &
Consol. Subs. v. Commissioner, 102 T.C. 149, 163 (1994);
Sundstrand Corp. & Subs. v. Commissioner, 96 T.C. 226, 352-353
(1991); Bausch & Lomb, Inc. v. Commissioner, 92 T.C. 525, 581
(1989), affd. 933 F.2d 1084 (2d Cir. 1991); Edwards v.
Commissioner, 67 T.C. 224, 230 (1976); sec. 1.482-1(b)(1), Income
Tax Regs. The Commissioner may make allocations under section
482 even in the absence of tax avoidance motives in order clearly
to reflect the respective incomes of members of the controlled
group. See Central Cuba Sugar Co. v. Commissioner, 198 F.2d 214,
215-216 (2d Cir. 1952), affg. in part and revg. in part 16 T.C.
882 (1951). Thus, establishment of a business purpose for a
transaction does not necessarily insulate the taxpayer from a
section 482 allocation. See Bausch & Lomb, Inc. v. Commissioner,
supra at 582.
The parties have stipulated that Mr. Canelos controlled
petitioner and the Canelos growers within the meaning of section
1.482-1(a)(3) through (5), Income Tax Regs. Accordingly, a
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