- 2 - income, relying on sec. 1.861-8(e)(7)(ii), Income Tax Regs. P apportioned those deductions in the same manner as the underlying expenses. Held: (1) Interest expense is apportioned under the asset method by prorating the assets between the statutory and residual groupings based on the income they produce; (2) swap losses are apportioned in the same manner as interest expense; (3) Swiss capital tax is apportioned in the same manner as interest expense; (4) sec. 1.861- 8(e)(2)(v), Income Tax Regs., does not apply to the exchange losses involved in this case, and the deductions are apportioned in the same manner as the underlying expenses to which they relate. Frederick E. Henry, Jeffrey M. O'Donnell, and Julie C. H. Walsh, for petitioner. Nancy B. Herbert and Reid M. Huey, for respondent. MEMORANDUM OPINION TANNENWALD, Judge: Respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax: Additions to Tax Year Deficiency Sec. 6661(a) 1985 $ 117,988.00 -- 1986 11,630,928.00 $1,429,687.00 1987 4,924,255.00 -- 1988 834,875.00 -- After concessions by the parties, the issue for decision is how various deductions should be allocated and apportioned between the subpart F income and non-subpart F income of petitioner's wholly owned subsidiary for the purposes of determiningPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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