Sunoco, Inc. and Subsidiaries - Page 42




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             applicability for the allocation and apportionment of                    
             expenses, losses, and other deductions, set forth in                     
             section 1.861-8(a), (b), and (c), Income Tax Regs., are                  
             based on the approach that an expense, loss, or other                    
             deduction should be allocated to a class of income,                      
             composed of less than the taxpayer's entire gross income,                
             as to which the deduction bears a factual relationship,                  
             and then, if necessary, apportioned between or among the                 
             statutory and residual groupings of gross income.  See sec.              
             1.861-8(a), (b), and (c), Income Tax Regs.  On the other                 
             hand, the rules that specifically govern the allocation                  
             and apportionment of interest expenses, with two limited                 
             exceptions, take the approach that interest expenses are                 
             related to all income-producing activities and properties                
             of the taxpayer and thus are allocable to all of the                     
             taxpayer's gross income.  See sec. 1.861-8(e)(2)(i) and                  
             (ii), Income Tax Regs.                                                   
                  The regulations state that the different approach                   
             for allocating interest expenses is based on the fact                    
             that "money is fungible and that interest expense is                     
             attributable to all activities and property regardless of                
             any specific purpose for incurring an obligation on which                
             interest is paid."  Sec. 1.861-8(e)(2)(i), Income Tax Regs.              
             Thus, the regulations use the phrase "money is fungible"                 






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