 | United States. Internal Revenue Service - 1963 - 1436 páginas
...section 482 of the 1954 Code (section 45 of the 1939 Code) which provides: In any case of two or more organizations, trades, or businesses (whether or not...affiliated) owned or controlled directly or indirectly by {lie same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income,... | |
 | United States. Tax Court - 1954 - 1284 páginas
...there» SEC. 45. ALLOCATION OF INCOME AND DEDUCTIONS. In any case of two or more organizations, trade*, or businesses (whether or not Incorporated, whether...affiliated) owned or controlled directly or Indirectly by the same Interests, the Commissioner Is authorized to distribute, apportion, or allocate gross Income,... | |
 | United States. Tax Court - 1961 - 1188 páginas
...ALLOCATION OF INCOME AND DEDUCTIONS. In any cusc of two or more organizations, trades, or buaineseus (whether or not incorporated, whether or not organized...affiliated) owned or controlled directly or Indirectly by the same interests, the Commissioner is authorized to distribute, apportion, or allocate gross income,... | |
 | United States. Congress. House. Committee on the Judiciary, United States. Congress. House. Committee on the Judiciary. Special Subcommittee on State Taxation of Interstate Commerce - 1961 - 678 páginas
...California, part II, bank and corporation tax law, chapter 13, paragraph 24735 : "In any case of two or more organizations, trades, or businesses (whether or not...affiliated) owned or controlled directly or indirectly by the same interests, the franchise tax board may distribute, apportion, or allocate gross income, deductions,... | |
 | United States. Internal Revenue Service - 1962 - 976 páginas
...TAXPAYERS. SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAXPAYERS. In any case of two or more organizations, trades, or businesses (whether or not...affiliated) owned or controlled directly or indirectly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross Income,... | |
 | United States. Congress. Senate. Committee on Finance - 1962 - 754 páginas
...to the "sham" operation problem. Section 482 contains just one sentence : In any case of two or more organizations, trades, or businesses, whether or not...whether or not affiliated, owned, or controlled directly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income,... | |
 | United States. Congress. Senate. Committee on Finance - 1962 - 1080 páginas
...apportion, or allocate gross income, deductions, credits, or allowances between controlled organizations whether or not incorporated, whether or not organized...the United States, and whether or not affiliated. These provisions or their counterparts have been part of the income tax law for many years. In addition,... | |
 | United States. Tax Court - 1963 - 1180 páginas
...cone of two or more organizations, trades, or businesses (whether or not Incorporated, whether or nut organized In the United States, and whether or not...affiliated) owned or controlled directly or Indirectly by the same Interests, the Secretary or hli delegate may distribute, apportion, or allocate groan Income,... | |
 | United States. Congress. Senate. Select Committee on Small Business - 1964 - 410 páginas
...contained in section 482 of the 1954 code (sec. 45 of the 1939 code) : "In any case of two or more organizations, trades, or businesses (whether or not...affiliated) owned or controlled directly or indirectly by the same interests, the Secretary or his delegate may distribute, apportion, or allocate gross income,... | |
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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... 
