Sunoco, Inc. and Subsidiaries - Page 21




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             by the excess of the company's total gross income,                       
             $36,565,327, over its interest income, $1,784,106, or                    
             $34,781,221, to arrive at the gross income ratio of 99.51                
             percent.                                                                 
                  Thus, in computing the second gross income ratio for                
             North Sea Sun Oil Co. under section 1.861-8(e)(2)(vi),                   
             Income Tax Regs., the ratio to be used if netting is                     
             permitted, the interest income earned by North Sea Sun Oil               
             Co. during 1986 was subtracted from both the numerator and               
             the denominator of the fraction.  The interest income                    
             earned during 1986 by each of the other 14 members of                    
             plaintiff's affiliated group was subtracted only from the                
             denominator of the fraction in computing the second gross                
             income ratio for each of those companies.  We infer from                 
             this that the interest income earned by North Sea Sun Oil                
             Co. in 1986 constituted gross income from sources without                
             the United States, whereas the interest income earned by                 
             each of the other members of petitioner's affiliated group               
             for 1986 constitutes gross income from sources within the                
             United States.                                                           
                  The following schedule summarizes the revenue impact                
             of the position of each of the parties with respect to the               
             subject issue.  It shows, based upon the parties'                        
             stipulation, the aggregate interest expense apportioned to               






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