The Coca-Cola Company, and Includible Subsidiaries - Page 1

                                   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 to                   






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