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Commissioner, 88 T.C. 252, 359 (1987). Whether respondent has
exceeded his discretion is a question of fact. See American
Terrazzo Strip Co. v. Commissioner, 56 T.C. 961, 971 (1971). In
reviewing the reasonableness of respondent's determination, the
Court focuses on the reasonableness of the result, not on the
details of the methodology used. See Bausch & Lomb, Inc. v.
Commissioner, supra at 582; Eli Lilly & Co. v. United States, 178
Ct. Cl. 666, 676, 372 F.2d 990, 997 (1967).
Should the taxpayer overcome the Commissioner's presumption
of correctness and prove that the deficiencies set forth in the
notice of deficiency are arbitrary, capricious, or unreasonable,
but fail to prove that alternative allocations it proposes
satisfy the arm's-length standard, the Court must determine from
the record the proper allocation of income between or among the
controlled entities. See, e.g., Sundstrand Corp. & Subs. v.
Commissioner, supra at 354; American Terrazzo Strip Co. v.
Commissioner, supra; Nat Harrison Associates, Inc. v.
Commissioner, 42 T.C. 601 (1964).
In the notices of deficiency, respondent calculated that
petitioner's commission income in total for the years in issue
should be increased from $10,095,719 to $22,699,824, an increase
of $12,604,105. Respondent now has adopted Dr. Daniel J.
Frisch's (Dr. Frisch) opinion that petitioner's commission income
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