id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-460	Cunningham, Laura	Use and Abuse of Section 704(c)	2022	35	.pdf	application/pdf	15156	643	56	Treasury further stated that because of the elective nature of the remedial allocation method, it cannot be viewed as the baseline for measuring abuse.53 Once the ceiling rule is considered inviolate, except at the election of the taxpayer, one might ask why the traditional method, which relies on Treasury's basic principle of tax following book, can ever be considered abusive. Yet, it is useful to keep in mind that at the heart of each is the mandate that tax allocations should follow book allocations, and that tax/book disparities should be avoided whenever possible and resolved as quickly as possible when they do arise.	cache/ftr-460.pdf	txt/ftr-460.txt