General Dynamics Corporation and Subsidiaries - Page 30

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               for which items of income and expense (including                       
               depreciation) are taken into account.  * * *                           
          See sec. 1.925(a)-1T(c)(6)(iii)(A), Temporary Income Tax Regs.,             
          supra.  Use of the taxpayer's accounting method is expressly                
          subject to subdivision (iii)'s definition of related costs that             
          taxpayers must take into account in calculating CTI.  Sec. 1.994-           
          1(c)(6)(i), Income Tax Regs.; see sec. 1.925(a)-1T(c)(6)(iii)(D),           
          Temporary Income Tax Regs., supra.  Thus, section 1.994-                    
          1(c)(6)(iii), Income Tax Regs., defines the costs related and               
          allocable to petitioners' export sales; such costs are not                  
          defined by petitioners' method of accounting.                               
               In addition to their misplaced reliance on subdivision (i)             
          of section 1.994-1(c)(6), Income Tax Regs., petitioners also                
          assert that section 1.861-8, Income Tax Regs., supports their               
          position that they are not required to account for prior year               
          period costs.  As stated above, Congress intended taxpayers                 
          exporting through DISC’s to allocate their income and costs to              
          export sales pursuant to the requirements of section 1.861-8,               
          Income Tax Regs.  Rather than address the substantive allocation            
          requirements of section 1.861-8, Income Tax Regs., as described             
          above, petitioners again concentrate their argument on their                
          accounting method.  Petitioners argue that section 1.861-8,                 
          Income Tax Regs., requires that the principles of annual                    
          accounting apply to income and cost allocations.  Petitioners               
          deducted the period costs in prior years in accordance with the             





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