73, 91 (1991). Based upon the court’s own research, this court, in the past, has not been called upon to reallocate income; however, the Seventh Circuit and the Tax Court have allowed courts to reallocate income in a section 482 case when necessary. See Eli Lilly & Co. v. Commissioner, 856 F.2d 855, 860 (7th Cir.1988) (“Where the evidence shows that neither side is correct, we think it would be unreasonable to restrict the court to acceptance or rejection of the Commissioner’s position in its entirety, rather than allowing the court to reallocate ‘in a manner the evidence ... demonstrates to be correct.’ Nat Harrison Assocs., [Inc. v. Commissioner of Internal Revenue,] 42 T.C. [601] at 618 [ (1964) ].”); Baldwin-Lima-Hamilton Corp. v. United States, 435 F.2d 182, 187 (7th Cir.1970) (<HOLDING>). Accordingly, there is no reason to grant
holding that a subsidiarys activities will be attributed to the foreign parent for purposes of determining the parents amenability to personal jurisdiction in new york holding that a parent must exercise some control over the subsidiarys activities which does not require that the subsidiary be controlled to an ultimate degree by its parent  although something more than mere passive investment by the parent is required the parent must have and exercise control and direction  over the affairs of its subsidiary in order for venue to be proper recognizing that entities holding intellectual property for parent company had no real economic substance and allowing taxation of a portion of income attributable to parent corporations business in the state holding that district court has the power to decide what portion of subsidiarys income should be reallocated to its parent holding that a subsidiarys contacts can be imputed for purposes of service of process where a parent uses the subsidiary to do what it otherwise would have done itself 