Trinova Corporation and Subsidiaries - Page 13

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          groupings according to asset values.5  Petitioner apportioned all           
          of AG's assets to the statutory grouping, because they all                  
          normally produce subpart F income.  It apportioned none of AG's             
          loan assets to the residual grouping, because, although they                
          sometimes produce non-subpart F income (in this case, foreign               
          exchange gain), it is impossible to predict whether there will be           
          gain or loss, based on the nature of foreign exchange rates.                
          According to petitioner, the loan assets do not normally produce            
          such gain.  Petitioner thus allocated the entire interest                   
          deduction, in the amount of $1,498,562, to gross subpart F                  
          income.                                                                     
               Respondent disagrees with petitioner's application of the              
          asset method.  While she agrees that the non-loan assets should             
          all be apportioned to the subpart F grouping, she reasons that              
          the loan assets should be apportioned in some manner between the            
          statutory and residual groupings, because they actually produced            
          both subpart F and non-subpart F income.  Respondent applies the            
          asset method by: (1) apportioning the non-loan assets all to the            


          5  The asset values are determined by an average of the asset               
          values at the beginning and the end of the year, unless this                
          method produces a "substantial distortion" of the asset values.             
          Sec. 1.861-8(e)(2)(v), Income Tax Regs.  Petitioner has computed            
          an average value for AG's assets based on monthly averages, which           
          differs by 0.6 percent from respondent's computation that follows           
          the exact wording of the regulations.  We find that 0.6 percent             
          is not a substantial distortion, and thus find respondent's                 
          computation of AG's average asset values, which we set forth                
          above, to be correct.                                                       




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