A sale1 of property that is not at market value2 is treated as being at market value if the control test is met, or if the tax advantage test is met3.
The control test is met if:
(1) the buyer is a body of persons4 over whom the seller has control5;
(2) the seller is a body of persons over whom the buyer has control;
(3) both the seller and the buyer are bodies of persons and some other person has control over both of them; or
(4) the seller and the buyer are connected persons6.
The tax advantage test is
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