[Code of Federal Regulations]
[Title 26, Volume 1]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.269-4]

[Page 592]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.269-4  Power of district director to allocate deduction, credit, 
or allowance in part.

    The district director is authorized by section 269(b) to allow a 
part of the amount disallowed by section 269(a), but he may allow such 
part only if and to the extent that he determines that the amount 
allowed will not result in the evasion or avoidance of Federal income 
tax for which the acquisition was made. The district director is also 
authorized to use other methods to give effect to part of the amount 
disallowed under section 269(a), but only to such extent as he 
determines will not result in the evasion or avoidance of Federal income 
tax for which the acquisition was made. Whenever appropriate to give 
proper effect to the deduction, credit, or other allowance, or such part 
of it which may be allowed, this authority includes the distribution, 
apportionment, or allocation of both the gross income and the 
deductions, credits, or other allowances the benefit of which was 
sought, between or among the corporations, or properties, or parts 
thereof, involved, and includes the disallowance of any such deduction, 
credit, or other allowance to any of the taxpayers involved.

[T.D. 6595, 27 FR 3597, Apr. 14, 1962]