General Dynamics Corporation and Subsidiaries - Page 23

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               are directly related to the production or sale of the                  
               export property and a portion of the related person's                  
               and the DISC's expenses not allocable to any specific                  
               item of income, such portion to be determined on the                   
               basis of the ratio of the combined gross income from                   
               the export property to the total gross income of the                   
               related person and the DISC.  [Fn. ref. omitted;                       
               emphasis added.]                                                       
          H. Rept. 92-533, at 74 (1971), 1972-1 C.B. 498, 538; S. Rept. 92-           
          437, at 107 (1971), 1972-1 C.B. 559, 619.  The regulation in                
          issue defines an ambiguous term and reflects congressional intent           
          as to the types of costs taxpayers must allocate to export sales            
          in calculating CTI.  Thus, the regulatory definition of CTI in              
          section 1.994-1(c)(6), Income Tax Regs., is a reasonable                    
          interpretation of section 994.                                              

               D.  Interpretation of the Regulatory Definition of "Combined           
          Taxable Income"                                                             
               Regulations that are valid exercises of the powers of the              
          Secretary have the force and effect of law.  Sim-Air, USA, Ltd.             
          v. Commissioner, 98 T.C. 187, 198 (1992).  The rules for                    
          interpreting a valid regulation are similar to those governing              
          the interpretation of statutes.  KCMC, Inc. v. FCC, 600 F.2d 546,           
          549 (5th Cir. 1979); Intel Corp. & Consol. Subs. v. Commissioner,           
          100 T.C. 616, 631 (1993), affd. 67 F.3d 1445 (9th Cir. 1995).               
          When construing a statute, or in this case a regulation, we are             
          to give effect to its plain and ordinary meaning unless to do so            
          would produce absurd results.  Green v. Bock Laundry Mach. Co.,             
          490 U.S. 504, 509 (1989); Exxon Corp. v. Commissioner, 102 T.C.             





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