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of <h1>Benefit denied when obtaining it was a principal purpose of the arrangement, unless consistent with agreement's object and purpose</h1> A benefit under the agreement will be denied for an item of income if, based on all relevant facts and circumstances, it is reasonable to conclude that obtaining that benefit was one of the principal purposes of any arrangement or transaction that directly or indirectly produced the benefit, unless it can be shown that granting the benefit in those circumstances would be consistent with the object and purpose of the relevant provisions of the agreement.
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