26 CFR §1.6662-5T — -5T Substantial and gross valuation misstatements under chapter 1 (temporary).

1. (a)-(e)(3) [Reserved]. For further information, see § 1.6662-5(a) through (e)(3).
2. (e)
   1. (4)Tests related to section 482
      1. (i)Substantial valuation misstatement. There is a substantial valuation misstatement if there is a misstatement described in § 1.6662-6 (b)(1) or (c)(1) (concerning substantial valuation misstatements pertaining to transactions between related persons).
      2. (ii)Gross valuation misstatement. There is a gross valuation misstatement if there is a misstatement described in § 1.6662-6 (b)(2) or (c)(2) (concerning gross valuation misstatements pertaining to transactions between related persons).
      3. (iii)Property. For purposes of this section, the term property refers to both tangible and intangible property. Tangible property includes property such as money, land, buildings, fixtures and inventory. Intangible property includes property such as goodwill, covenants not to compete, leaseholds, patents, contract rights, debts, choses in action, and any other item of intangible property described in § 1.482-4(b).
3. (f)-(h) [Reserved]. For further information, see § 1.6662-5 (f) through (h).
4. (i)[Reserved]
5. (j)Transactions between persons described in section 482 and net section 482 transfer price adjustments. For rules relating to the penalty imposed with respect to a substantial or gross valuation misstatement arising from a section 482 allocation, see § 1.6662-6.