482. Without restricting the generality of section 479, in determining the tax consequences to a person as is reasonable in the circumstances in order to deny a tax benefit that would, but for this chapter, result, directly or indirectly, from an avoidance transaction,(1) any input tax refund or any deduction in computing tax or net tax payable may be allowed or disallowed, in whole or in part;
(2) any refund or deduction referred to in paragraph 1, or a part thereof, may be allocated to any person;
(3) the nature of any payment or other amount may be recharacterized; and
(4) the tax effects that would otherwise result from the application of other provisions of this Title may be ignored.