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the provisions of any treaty to which the United States is a party, in lieu of the 3-year period of limitation prescribed in subsection (a), the period shall be 10 years from the date prescribed by law for filing the return for the year in which such taxes were actually paid or ...
(3) Related person -- For purposes of this subsection, the term "related person" means any person bearing a relationship to the taxpayer described in section 267(b) or 707(b)(1). (4) Treatment of certain transactions -- This section shall not apply to any exchange which is part of a...
(3) Related person — For purposes of this subsection, the term “related person” means any person bearing a relationship to the taxpayer described in section 267(b) or 707(b)(1). (4) Treatment of certain transactions — This section shall not apply to any exchange which is part of a...
Certain attribution rules apply for purposes of the ATB Activity Test. All activities conducted by persons related to the taxpayer are attributed to the taxpayer for purposes of the test. A "related person" means a person who is related ...