In gen- eral Sample Clauses

In gen- eral. For purposes of this section, an in- terest in or stock of an organization is subject to conditions which substan- tially restrict or limit the right to dis- pose of such interest or stock and which run in favor of another person if the condition extends directly or indi- rectly to such person preferential rights with respect to the acquisition of the direct owner’s (or the record owner’s) interest or stock. For a condi- tion to be in favor of another person it is not necessary that such person be extended a discriminatory concession with respect to price. A right of first refusal with respect to an interest or stock in favor of another person is a condition which substantially restricts or limits the direct or record owner’s right of disposition which runs in favor of such person. Further, any legally en- forceable condition which prohibits the direct or record owner from disposing of his or her interest or stock without the consent of another person will be considered to be a substantial limita- tion running in favor of such person.

In gen- eral. The Secretary may compromise a liability on any of the following three grounds.

In gen- eral. In determining the true taxable income of a controlled taxpayer, the standard to be applied in every case is that of a taxpayer dealing at arm’s length with an uncontrolled taxpayer. A controlled transaction meets the arm’s length standard if the results of the transaction are consistent with the results that would have been realized if uncontrolled taxpayers had engaged in the same transaction under the same circumstances (arm’s length result). However, because identical trans- actions can rarely be located, whether a transaction produces an arm’s length result generally will be determined by reference to the results of comparable transactions under comparable cir- cumstances. See § 1.482–1(d)(2) (Stand- ard of comparability). Evaluation of whether a controlled transaction pro- duces an arm’s length result is made pursuant to a method selected under the best method rule described in § 1.482–1(c).

In gen- eral. The term business use percentage means the percentage of the use of any listed property which is qualified busi- ness use as described in paragraph (d)(2) of this section.