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The code section exists for 2 reasons. One is that when two
entities are controlled by the same person or group, the end result
is consistent within a particular transaction. At its most basic level
if one group experiences an expense, the other controlled group
experiences gain. The other reason is so that in the event of a
sale within a controlled group (related party group) that results in
a loss, the loss doesnt get recognized until the item sold leaves
the controlled group. This means you cant sell something to
yourself and take a loss on the transaction. Additionally IRC 267
defines what are to be considered related parties and it is there
that we will focus our attention.