been an uncontrolled taxpayer dealing at arm’s length with another uncontrolled taxpayer.” Ruddick Corp. v. United States, 226 Ct.Cl. 426, 643 F.2d 747, 750 (1981) (quoting Treas.Reg. § 1.482-l(c)) (emphasis omitted). Even if plaintiff inadvertently treated its parent in a non-arm’s length manner, section 482 applies. Section 482 in the Internal Revenue Code is the specific provision that may be used to adjust the prices at which goods and services are transferred between entities owned or controlled by the same interests. It is a well-recognized rule of statutory construction that a specific provision controls when the same subject matter is addressed by a more general provision. See Bulova Watch Co. v. United States, 365 U.S. 753, 758, 81 S.Ct. 864, 867-68, 6 L.Ed.2d 72 (1961) (<HOLDING>); Norman J. Singer, Sutherland Statutory
holding that in a proceeding to recover taxes from a nonbankrupt taxpayer the taxpayer has the burden of proving that his taxes complied with the internal revenue code holding wills more specific provision prevails over general provision recognizing that the statute of limitations provision of the aedpa is an affirmative defenses rather than jurisdictional holding that interest accruing on an overpayment of taxes attributable to an unused excess profits credit carryback was governed by a specific provision of the internal revenue code rather than by a general provision holding that general obligation to pay money under a disputed provision of the tax code was not a taking