Under Section 482 of the U.S. Internal Revenue Code, the details of transactions are ignored and taxable profit is determined by allocating shares of the total profit.

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Section 482 of the U.S. Internal Revenue Code allows the IRS to adjust income, deductions, credits, or allowances between related entities to prevent evasion of taxes or to clearly reflect income. It does not ignore the details of transactions but rather ensures that transactions between related parties are conducted at arm's length, reflecting the true economic value of those transactions.