Sunoco, Inc. and Subsidiaries - Page 29




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             step in determining taxable income from a specific source                
             or activity is to allocate and apportion the taxpayer's                  
             "expenses, losses, and other deductions" to each of the                  
             groupings of gross income.  Sec. 1.861-8(a)(2), (b), and                 
             (c), Income Tax Regs.  Taxable income from a particular                  
             source or activity is the difference between the aggregate               
             items of gross income in that grouping and the sum of the                
             expenses, losses, and other deductions that are properly                 
             allocated and apportioned thereto, and a ratable portion                 
             of any expenses, losses, or other deductions that cannot                 
             definitely be allocated to an item or class of gross                     
             income.  See secs. 861(b), 862(b); secs. 1.861-1, 1.861-                 
             8(a)(1), Income Tax Regs.                                                
                  The regulations provide rules of general applicability              
             governing the allocation and apportionment of expenses,                  
             losses, and other deductions, see sec. 1.861-8(a), (b),                  
             (c), and (d), Income Tax Regs., as well as rules governing               
             the allocation and apportionment of specific deductions,                 
             see sec. 1.861-8(e)(2) through (11), Income Tax Regs.                    
             Specific rules for the allocation and apportionment of                   
             interest expense are provided in section 1.861-8(e), Income              
             Tax Regs.                                                                
                  The principal rule of general applicability is that a               
             taxpayer's expenses, losses, and other deductions are to be              






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