- 30 - 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 thePage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
Last modified: May 25, 2011