Sunoco, Inc. and Subsidiaries - Page 33




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                  taxpayer for payment of the debt.  When money is                    
                  borrowed for a specific purpose, such borrowing                     
                  will generally free other funds for other                           
                  purposes and it is reasonable under this approach                   
                  to attribute part of the cost of borrowing to                       
                  such other purposes.  For the method of                             
                  determining the interest deduction allowed to                       
                  foreign corporations under section 882(c), see                      
                  sec. 1.882-5. [Sec. 1.861-8(e)(2)(i), Income Tax                    
                  Regs.]                                                              

             This is the provision of the regulations on which                        
             petitioner principally relies, sec. 1.861-8(e)(2)(i),                    
             Income Tax Regs.  Based on the above approach, the                       
             regulations provide as follows:                                          

                  the aggregate of deductions for interest shall                      
                  be considered related to all income producing                       
                  activities and properties of the taxpayer and,                      
                  thus, allocable to all the gross income which                       
                  the income producing activities and properties                      
                  of the taxpayer generate, have generated, or                        
                  could reasonably have been expected to generate.                    
                  [Sec. 1.861-8(e)(2)(ii), Income Tax Regs.]                          

                  After stating the general rule in section 1.861-                    
             8(e)(2)(i), Income Tax Regs., that interest expense is                   
             "allocable to all gross income" of the taxpayer, the                     
             regulations provide various methods to apportion the                     
             taxpayer's interest expense between the statutory                        
             grouping of gross income (or among the statutory groupings               
             of gross income) and the residual grouping.  See sec.                    
             1.861-8(e)(2)(v) and (vi), Income Tax Regs.  Under the                   







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