Sunoco, Inc. and Subsidiaries - Page 14




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             for an affiliated group, the numerator of the limiting                   
             fraction is an amount equal to the total of the separate                 
             taxable incomes of the members of the group from sources                 
             without the United States, with certain adjustments that                 
             are not material to this case.  See sec. 1.1502-4(d)(1),                 
             Income Tax Regs.  The denominator of the limiting fraction               
             under section 904(a) is the consolidated taxable income of               
             the group computed in accordance with section 1.1502-11,                 
             Income Tax Regs.  Sec. 1.1502-4(d)(2), Income Tax Regs.                  
             Thus, for each of the subject consolidated return years,                 
             petitioner was required to compute the "taxable income from              
             sources without the United States" of each member of its                 
             affiliated group of corporations.  Sec. 904(a).  The total               
             of those amounts is the numerator of the limiting fraction               
             under section 904(a).                                                    
                  In these proceedings, petitioner seeks to make two                  
             changes in the method used to allocate and apportion                     
             interest expenses for purposes of computing each member's                
             taxable income from sources without the United States.                   
             First, petitioner seeks to apportion the interest expenses               
             of each member of its affiliated group using the asset                   
             method described in section 1.861-8(e)(2)(v), Income Tax                 
             Regs., for tax years 1982, 1983, and 1984, and using one                 
             of the optional gross income methods described by section                






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