Allocation of Income and Deductions among Taxpayers under Section 482 of the United States Internal Revenue Code: Alerting the Courts to the Role of Contractual Interpretation Law in the Transfer Pricing Arm’s Length Comparability Analysis

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This article discusses the task of identifying controlled transactions under review by the Commissioner of the Internal Revenue Service. In particular, it aims to alert courts as to the necessary role of contractual interpretation law in determining the true nature of such controlled transactions.