- 34 - See secs. 1.263A-1(e)(3)(i), 1.451-1(d)(6)(ii), Income Tax Regs. Next, we must define “reasonable allocation” for purposes of sections 1.263A-1(e)(3)(i) and 1.451-1(d)(6)(ii), Income Tax Regs., and then determine whether Qwest’s incremental cost allocation method satisfies that definition. II. Definition of “Reasonable Allocation” for Purposes of Sections 1.263A-1(e)(3)(i) and 1.451-1(d)(6)(ii), Income Tax Regs. Respondent argues that the language of section 1.263A- 1(g)(3), Income Tax Regs., requires that the reasonableness standard of section 1.263A-1(f)(4), Income Tax Regs., governs the first level allocations in the present case. In the alternative, respondent contends that the reasonableness standard of section 1.263A-1(f)(4), Income Tax Regs., should be incorporated into the undefined phrase “reasonable allocation” in sections 1.263A- 1(e)(3)(i) and 1.451-3(d)(6)(ii), Income Tax Regs. To support this contention, respondent notes the parallel structure of the regulations under sections 263A and 451 and cites legislative history. On the other hand, petitioners contend that because “reasonable allocation” is not defined by sections 1.263A- 1(e)(3)(i) and 1.451-3(d)(6)(ii), Income Tax Regs., “reasonable” should be interpreted using its ordinary meaning. A. The Language of Section 1.263A-1(g)(3), Income Tax Regs. Respondent argues that the language of section 1.263A- 1(g)(3), Income Tax Regs., requires that the reasonablenessPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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