- 454 -                                         
          conforms with business realities will be respected for tax                   
          purposes.  See Frank Lyon Co. v. United States, 435 U.S. 561,                
          584-585 (1978).                                                              
          B.  Section 267                                                              
               Section 267 and its predecessors were enacted to correct                
          what Congress considered the abusive and frequently employed                 
          practice of creating losses for purposes of avoiding income taxes            
          through transactions between related persons and groups.  Because            
          of the identity of economic interests of such parties and the                
          control taxpayers had over the persons or entities involved, the             
          transfers were usually not thought to result in economically                 
          genuine realization of loss.  See McWilliams v. Commissioner, 331            
          U.S. 694, 699 (1947); H. Rept. 704, 73d Cong., 2d Sess., 1939-1              
          C.B. (Part 2) 554, 571.  To prevent tax avoidance, Congress, in              
          section 267 and its statutory predecessors, denied deductions for            
          losses on all sales or exchanges between specified related                   
          persons, regardless of such persons' subjective intent.  Thus,               
          where section 267 is applicable, it is immaterial whether the                
          particular transaction involved is a bona fide, arm's-length                 
          transaction.  See McWilliams v. Commissioner, supra.                         
               Generally, section 267(a) provides that no deduction shall              
          be allowed for any loss realized from the sale or exchange of                
          property between related persons or entities.  Included among the            
          relationships are transactions between members of a family and               
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