Transcription of Internal Revenue Service, Treasury §1.482–0
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Internal Revenue Service, Treasury §1.482–0
Internal Revenue Service, Treasury 0. agreement shall be binding on the par- (i) Market share strategy. ties except upon a showing of fraud, (ii) Different geographic markets. malfeasance, or misrepresentation of (A) In general. (B) Example. material fact. (C) Location savings. [ 8608, 60 FR 40079, Aug. 7, 1995] (D) Example. (iii) Transactions ordinarily not accepted 5 Effective dates. as comparables. (A) In general. Sections 1, 2, 3, and (B) Examples. 4 are effective for Consent Agree- (e) Arm's length range. ments signed on or after December 27, (1) In general. 1994. For Consent Agreements signed (2) Determination of arm's length range. before December 27, 1994, see 1, (i) Single method. 2, 3, 4, and 5 (as (ii) Selection of comparables. (iii) Comparables included in arm's length contained in the 26 CFR part 1 edition range.)
573 Internal Revenue Service, Treasury §1.482–0 agreement shall be binding on the par-ties except upon a showing of fraud, malfeasance, or misrepresentation of
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