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               The regulations also provide that taxes either are or are              
          not to be regarded as income taxes in their entirety for all                
          persons subject to the taxes.  See sec. 1.901-2(a), Income Tax              
          Regs.  Respondent does not interpret this provision as requiring            
          that, in order to qualify as an income tax, a tax in question               
          must satisfy the predominant character test in its application to           
          all taxpayers.  Rather, respondent interprets this provision as             
          requiring that in order to qualify as an income tax a tax must              
          satisfy the predominant character test in its application to a              
          substantial number of taxpayers.                                            
               On brief, respondent explains the net income test as                   
          follows:  PRT satisfies the net income test if its base is                  
          computed by reducing gross receipts to permit recovery of                   
          significant costs and expenses attributable to gross receipts,              
          or, if some of these costs and expenses are not deductible,                 
          recovery of such costs and expenses computed under a method that            
          is likely to produce an amount approximating or exceeding the               
          nondeductible costs or expenses.                                            
               The parties have stipulated that PRT meets the realization             
          and gross receipts requirements of section 1.901-2(b)(2), (3),              
          Income Tax Regs., that PRT constitutes a compulsory payment                 
          7(...continued)                                                             
               provides allowances that effectively compensate for                    
               nonrecovery of such significant costs or expenses, is                  
               considered to permit recovery of such costs or                         
               expenses. * * *                                                        
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