- 34 - minor physical differences. The difference in price relating to the minor differences in physical properties can be quantified with definite and reasonably ascertainable adjustments. See sec. 1.482-2A(e)(2)(ii), Example (3), Income Tax Regs. ("Since minor physical differences in the product generally have a definite and reasonably ascertainable effect on prices, such differences do not normally render the uncontrolled sales noncomparable to the controlled sales."). The record demonstrates that the only differences in PCA's within each product category were the particular components used on each individual PCA and the time required to process PCA's on the manufacturing line. We are persuaded that these differences can be corrected with adjustments to Compaq U.S. standard costs. The Compaq U.S. standard cost of labor and overhead is equal to the time required to process a given PCA multiplied by the Compaq U.S. hourly labor and overhead rate. The Compaq U.S. standard material cost for a given PCA is the sum of the unburdened purchase order prices for each and every component used on the PCA as set forth in the bill of materials. Thus, according to petitioner, the Compaq U.S. standard costs account for differences in the time required to process a PCA and in the cost of the materials on the PCA. Based on the uncontrolled purchases of 3.6 million PCA's, the turnkey equivalent price of PCA's purchased from unrelatedPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
Last modified: May 25, 2011