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investment in U.S. possessions, and consequently, we find that
Q&A-12 is not inconsistent with any stated congressional intent.
Q&A-12 could have been written to require simply that
expenditures be allocated and apportioned in a manner consistent
with the rules set forth in section 1.861-6, Income Tax Regs.,
but it was not.
The fact that other methods might also be reasonable, or
even preferable, however, does not warrant our overturning a
regulation which itself has a reasonable basis. Brown & Root v.
TVA, 681 F.2d 1313, 1316-1317 (11th Cir. 1982). Even presuming
that we might disagree with the results of applying the PCR in
the instant case, we would not substitute our own construction of
the statute for that of the Secretary where the regulation
implements the congressional mandate in a reasonable manner. See
Florida Manufactured Housing Association, Inc. v. Cisneros, 53
F.3d at 1572-1573. Respondent may not ignore the requirements
set forth in the plain language of the regulations any more than
petitioner or other taxpayers. Intel Corp. & Consol. Subs. v.
Commissioner, 100 T.C. at 630.
We cannot conclude that the regulation at issue presents an
impermissible construction of section 936(h). The Commissioner
was delegated the authority to make choices among reasonable
alternatives in interpreting section 936(h) and did so.
After considering the regulation in light of the language of
section 936(h) and the purpose behind it, we are satisfied that
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