Sunoco, Inc. and Subsidiaries - Page 37




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             the subject regulation which is based upon the fungibility               
             of money approach, and, absent an express rule to the                    
             contrary, the term "interest" should be recognized to mean               
             net interest expense; i.e., gross interest expense less                  
             interest income.                                                         
                  Petitioner asserts that the following "simplified                   
             example", demonstrates that recognizing "interest" or "the               
             cost of borrowing" as net interest expense, implements the               
             fungibility of money principle:                                          

                  Assume * * * that a business needs $800,000,                        
                  and has $1 million in short-term instruments                        
                  bearing interest at 10 percent per year, and the                    
                  capacity to borrow funds with no fees and at 10                     
                  percent per year.  The business can obtain the                      
                  $800,000 by reducing its holding of short-term                      
                  interest bearing instruments or by borrowing.                       
                  Either choice has exactly the same effect on the                    
                  net income of the business.  If the business                        
                  borrows, interest expense will increase by                          
                  $80,000 per year; if the business sells the                         
                  instruments, interest income will decrease by                       
                  $80,000 per year.                                                   

             Petitioner argues that the two sources of funds in the                   
             above example, incurring debt and selling short-term                     
             interest bearing assets, are fungible and should be treated              
             as fungible under the source rules, as would take place by               
             recognizing interest as net interest expense.  Petitioner                
             also argues that "a corollary to the fungibility of these                
             two sources of funds is the fact that reduced interest                   






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