The Coca-Cola Company, and Includible Subsidiaries - Page 32

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          Burlington N. R.R. v. Oklahoma Tax Commn., 481 U.S. 454, 461                
          (1987); United States v. NEC Corp., supra at 1498.                          
               Thus, the party who seeks to convince a court to adopt a               
          reading of a statute which is at odds with its plain meaning                
          labors under a heavy burden.  United States v. NEC Corp., supra             
          at 1499.                                                                    
               Consistent with the foregoing, we examine the historical               
          development of section 936 and determine whether the regulation             
          implements the congressional mandate in a reasonable manner.                
               D.  Analysis:  Section 1.936-6(b)(1), Q&A-1 & -12, Income              
          Tax Regs.                                                                   
               Section 936 has its genesis in section 262 of the Revenue              
          Act of 1921, ch. 136, 42 Stat. 271, which exempted a U.S.                   
          corporation from Federal taxes on foreign-source income if it               
          derived at least 80 percent of its income from sources within a             
          possession and satisfied certain other requirements.  The                   
          requirements for exemption from tax as a possessions corporation            
          were carried forward without material change into section 931 of            
          the Internal Revenue Code of 1954.  In the Tax Reform Act of                
          1976, Congress eliminated the exemption and in its place enacted            
          the tax credit mechanism of section 436.  Tax Reform Act of 1976,           
          Pub. L. 94-455, sec. 1051, 90 Stat. 1643.                                   
               Congressional intent for section 931 and its predecessors              
          consistently has been the encouragement of American business                
          investments in possessions of the United States.  American                  





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