- 28 -
its origin, or its purpose. See Faltesek v. Commissioner, 92
T.C. at 1210-1211.
We have considered the remaining arguments of the parties
and, to the extent that they have not been addressed herein, find
them to be either not germane or unconvincing.
In light of the above, we hold that the Regulation is valid
and, since petitioner has failed to follow its provisions, we
further hold that petitioner is not entitled to its claims for
additional FSC commission expenses, in whole or in part, for the
taxable years at issue. Accordingly, respondent's cross-motion
is granted, and petitioner's motion is denied.
To reflect the foregoing,
An order granting
respondent's cross-motion for
partial summary judgment and
denying petitioner's motion
for partial summary judgment will
be issued.
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