Sunoco, Inc. and Subsidiaries - Page 32




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             each grouping.  See sec. 1.861-8(b)(5), (c)(2), Income                   
             Tax Regs.                                                                
                  Thus, under the rules of general applicability, the                 
             approach of the regulations, with several exceptions, is                 
             that every deduction has a definite factual relationship to              
             a particular class of gross income which constitutes less                
             than all of the taxpayer's gross income.  Based upon that                
             approach, the rules of general applicability require each                
             deduction to be allocated to the related class of gross                  
             income and to be apportioned, on some reasonable basis, to               
             the statutory and residual groupings of gross income.                    
                  The regulations take a different approach in the                    
             specific rules governing the allocation and apportionment                
             of interest expenses, set forth in section 1.861-8(e)(2),                
             Income Tax Regs.  The regulations describe this approach                 
             as follows:                                                              

                       (2) Interest–-(i)  In general.  The method                     
                  of allocation and apportionment for interest set                    
                  forth in this paragraph (e)(2) is based on the                      
                  approach that money is fungible and that interest                   
                  expense is attributable to all activities and                       
                  property regardless of any specific purposes for                    
                  incurring an obligation on which interest is                        
                  paid.  This approach recognizes that all                            
                  activities and property require funds and that                      
                  management has a great deal of flexibility as to                    
                  the source and use of funds.  Normally, creditors                   
                  of a taxpayer subject the money advanced to the                     
                  taxpayer to the risk of the taxpayer's entire                       
                  activities and look to the general credit of the                    






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