Computervision International Corp. - Page 49

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               deductions definitely related, and therefore allocated                 
               and apportioned, thereto, and (b) a ratable part of any                
               other expenses, losses, or other deductions which are                  
               not definitely related to a class of gross income,                     
               determined in a manner consistent with the rules set                   
               forth in * * * [section] 1.861-8, [Income Tax Regs.].                  
               [Sec. 1.994-1(c)(6)(iii), Income Tax Regs.]                            
          Interest is among the expenses subject to apportionment under the           
          rules set forth in section 1.861-8, Income Tax Regs.  Sec. 1.861-           
          8(e)(2), Income Tax Regs.  The regulation apportions interest               
          “based on the approach that money is fungible and that interest             
          expense is attributable to all activities and property regardless           
          of any specific purpose for incurring an obligation on which                
          interest is paid.”  Id.  Although the pertinent provisions of               
          section 1.861-8(e)(2), Income Tax Regs., do not specifically                
          provide that the interest expense subject to apportionment is the           
          taxpayer’s interest expense net of interest income, rather than             
          gross interest expense, we concluded in Bowater, Inc. v.                    
          Commissioner, 101 T.C. 207 (1993), that a taxpayer’s net interest           
          expense was the appropriate interest expense to be apportioned.             
          We reasoned that the interest expense net of interest income                
          represents a taxpayer’s actual cost of borrowing and noted that             
          interest is assumed to be fungible for purposes of the                      
          regulation.  Id. at 211, 214-215.  Accordingly, we held that, for           
          purposes of the 50 percent of CTI method, a taxpayer may                    
          apportion a ratable part of net, rather than gross, interest                
          expense to its qualified export receipts in calculating CTI.  Id.           
          at 214-215.                                                                 




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