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INTERNAL REVENUE CODE OF 1954
and chapter 2 of the Internal Revenue Code of 1939 shall be treated as the corresponding provisions of the Internal Revenue Code of 1939. (c) ADJUSTMENTS UNDER REGULATIONS.—In the case of any change described in subsection (a), the taxpayer may, in such manner and subject to such conditions as the Secretary or his delegate may by regulations prescribe, take the adjustments required by subsection (a)(2) into account in computing the tax imposed by this chapter for the taxable year or years permitted under such regulations. (d) EXCEPTION FOR CHANGE TO INSTALLMENT BASIS.—This section shall not apply to a change to which section 453 (relating to change to installment method) applies. SEC. 482. ALLOCATION OF INCOME AND DEDUCTIONS AMONG TAX. PAYERS.
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, the Secretary or his delegate may distribute, apportion, or allocate gross income, deductions, credits, or allowances between or among such organizations, trades, or businesses, if he determines that such distribution, apportionment, or allocation is necessary in order to prevent evasion of taxes or clearly to reflect the income of any of such organizations, trades, or businesses.
,§ 481(b)(3)(C)
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