106 T.C. No. 1 UNITED STATES TAX COURT THE COCA-COLA COMPANY, AND INCLUDIBLE SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 299-94. Filed January 4, 1996. P filed a motion for partial summary judgment relating to the computation of combined taxable income under sec. 936(h)(5)(C)(ii), I.R.C., with respect to syrup and soft-drink concentrate produced by P's sec. 936, I.R.C., subsidiary, Caribbean Refrescos, Inc. 1. Held: Sec. 1.936-6(b)(1), Q&A-12, Income Tax Regs., governs the computation of combined taxable income with respect to sales of component concentrate to unrelated third parties. 2. Held, further, sec. 1.936-6(b)(1), Q&A-12, Income Tax Regs., requires U.S. affiliate expenses to be allocated and apportioned to the component concentrate by applying the production cost ratio toPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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