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administrative expenses, respondent's representatives would
review and analyze the information.
After discussions and negotiations with regard to the
information, Exxon's and respondent's representatives reached
agreement as to allocation of Exxon's administrative expenses
between U.S. and foreign sources. Pursuant thereto, Exxon’s
proratable expenses were reallocated to Exxon’s foreign source
income in the following amounts:
Administrative Expenses Reallocated
Year To Foreign Source Income
1972 $38,375,438
1973 46,152,229
1974 53,111,300
1975 40,790,620
1976 45,235,003
Other Sourcing Adjustments
The third major agreed adjustment (the so-called "other
sourcing adjustments”) involves for 1972 through 1977 the
characterization or allocation of certain expenses of Exxon's
affiliated companies as between U.S. and foreign sources.
Similar to the G&G and proratables adjustments, Exxon’s and
respondent’s representatives generally agreed as to the
applicable law relating to the other sourcing adjustments. Upon
receipt during the audits from Exxon's representatives of
information relating to expenses of Exxon's affiliated companies,
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