Where a deduction for a payment (such as for services) is denied on audit, a single amount may be taxed more than once. Taxpayers in such situations may seek a correlative adjustment to the tax treatment of the payment by the recipient so as to avoid or mitigate duplicative income inclusions. Unfortunately, such correlative adjustments are commonly denied when the change in the payor's tax treatment does not clearly justify a change in treatment of the payee. In FAB Holdings v. Commissioner (TC Memo 2021-135), circumstances indicated an attempt to obtain more favorable tax treatment through a tax-motivated structure, and the petitioners were unable to obtain any correlative adjustment. The decision underscores the potential for such structures to backfire.