Background on Regulations Under Sections 482, 483, and 2032A of the Internal Revenue Code: Scheduled for a Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance on April 27, 1981

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U.S. Government Printing Office, 1981 - 19 lappuses

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11. lappuse - The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of relevant facts.
4. lappuse - Secretary or his delegate 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 such organizations, trades, or businesses.
5. lappuse - The standard to be applied in every case is that of an uncontrolled taxpayer dealing at arm's length with another uncontrolled taxpayer.
4. lappuse - 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...
2. lappuse - That in any case of two or more related trades or businesses (whether unincorporated or incorporated and whether organized in the United States or not) owned or controlled directly or indirectly by the same interests, the Commissioner may...
16. lappuse - In the case of livestock operations, the carrying capacity of the land; (7) Where the land is timbered, whether the timber is comparable to that on the subject property; (8) Whether the property as a whole is unified or whether it is segmented, and where segmented, the availability of the means necessary for movement among the different segments; (9) The number, types, and conditions of all buildings and other fixed improvements located on the properties and their location as it affects efficient...
5. lappuse - controlled' includes any kind of control, direct or indirect, whether legally enforceable, and however exercisable or exercised. It is the reality of the control which is decisive, not its form or the mode of its exericse. A presumption of control arises if income or deductions have been arbitrarily shifted.
5. lappuse - The purpose of section 482 is to place a controlled taxpayer on a tax parity with an uncontrolled taxpayer, by determining, according to the standard of an uncontrolled taxpayer, the true taxable income from the property and business of a controlled taxpayer.
15. lappuse - The formula provided by subparagraph (A) shall not be used — (i) where it is established that there is no comparable land from which the average annual gross cash rental...
15. lappuse - FARMS.— (A) IN GENERAL. — Except as provided in subparagraph (B), the value of a farm for farming purposes shall be determined by dividing — (i) the excess of the average annual gross cash rental for comparable land...

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