Controlled taxpayer

Controlled taxpayer means any one of two or more taxpayers owned or controlled directly or indirectly by the same interests, and includes the taxpayer that owns or controls the other taxpayers. Uncontrolled taxpayer means any one of two or more taxpayers not owned or controlled directly or indirectly by the same interests.
means any one of two or more taxpayers owned or controlled directly or indirectly by the same interests, and includes the taxpayer that owns or controls the other taxpayers.Uncontrolled taxpayermeans any one of two or more taxpayers not owned or controlled directly or indirectly by the same interests.

Source

26 CFR § 1.482-1


Scoping language

None
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