Sunoco, Inc. and Subsidiaries - Page 31




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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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