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statutory grouping or in each of the statutory groupings
and to gross income (within the class) which is in the
residual grouping." Sec. 1.861-8(c)(1), Income Tax Regs.
This attribution must reflect to a reasonably close extent
the factual relationship between the deduction and the
grouping of gross income. See id. The method of
apportionment for a particular deduction can take into
consideration various bases and factors, such as a
comparison of units sold attributable to the statutory
grouping and to the residual grouping, a comparison of
the amount of gross sales or receipts, a comparison of the
costs of goods sold, a comparison of profit contribution,
a comparison of expenses incurred, assets used, salaries
paid, space utilized, and time spent which are attributable
to the activities or properties giving rise to the class of
gross income, and a comparison of the amount of gross
income in the statutory grouping with the amount in the
residual grouping. See id.
Finally, if the deduction is not definitely related to
any gross income, then the regulations provide that it is
to be apportioned ratably between the statutory grouping
and (or among the statutory groupings) and the residual
grouping in proportion to the amount of gross income in
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