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Section 482 of the Internal Revenue Code: Reallocation of Income [ edit ] Section 482 of the Internal Revenue Code allows for a reallocation of income from the Loan-Out corporation to the individual, if necessary to avoid unintended tax evasion , or to more reasonably reflect the genuine revenues generated by the corporation.
Section 482 applies to all transactions between related parties and commonly controlled parties, regardless of taxpayer intent, according to regulatory guidance. To avoid tax evasion or to clearly reflect their income, the IRS may change the income, deductions, credits, or allowances of frequently managed taxpayers under Section 482 of the Code ...
The tax statutes were re-codified by an Act of Congress on February 10, 1939 as the "Internal Revenue Code" (later known as the "Internal Revenue Code of 1939"). The 1939 Code was published as volume 53, Part I, of the United States Statutes at Large and as title 26 of the United States Code.
Section 7805 of the Internal Revenue Code gives the United States Secretary of the Treasury the power to create the necessary rules and regulations for enforcing the Internal Revenue Code. [2] These regulations, including but not limited to the "Income Tax Regulations," are located in Title 26 of the Code of Federal Regulations, or "C.F.R ...
John Clark. Section 482 of the Income and Corporation Taxes Act 1970. Institute of Taxation. 1980. Google; Halsbury's Laws of England. Fourth Edition. Butterworths. London. 1978. Volume 23. Title "Income Taxation". Passim. Reviewed at "Reviews" (1979) 123 The Solicitors' Journal 46 (19 January 1979). 1983-84 British Master Tax Guide. CCH ...
The tax gap is the difference between the amount of tax legally owed and the amount actually collected by the government. The tax gap in 2006 was estimated to be $450 billion. [125] The tax gap two years later in 2008 was estimated to be in the range of $450–$500 billion and unreported income was estimated to be approximately $2 trillion. [126]
Commissioner v. Flowers, 326 U.S. 465 (1946), was a Federal income tax case before the Supreme Court of the United States. [1] The Court held that in order to deduct the expense of traveling under § 162 of the Internal Revenue Code, the expense must be incurred while away from home, and must be a reasonable expense necessary or appropriate to the development and pursuit of a trade or business.
Commissioner, 499 U.S. 554, 559 (1991), the Supreme Court, interpreting section 1001(a) of the tax code, stated: In order to avoid the cumbersome, abrasive, and ...