Sunoco, Inc. and Subsidiaries - Page 50




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             provisions define "gross income from sources within the                  
             United States" and "gross income from sources without the                
             United States" to include all of the interest income earned              
             by the taxpayer during the taxable year.  Secs. 1.861-2(a),              
             1.862-1(a), Income Tax Regs.  In computing gross income                  
             from sources within and without the United States, neither               
             the statute nor the regulations contemplate that the                     
             portion of the taxpayer's gross income consisting of                     
             interest income for the year will be reduced or entirely                 
             offset by interest expenses.                                             
                  As shown in the hypothetical example discussed above,               
             such a reduction of the amount of the taxpayer's gross                   
             income would be necessary in a netting computation.                      
             Otherwise, the computation would overstate the taxpayer's                
             taxable income for the year by the interest income that                  
             is offset by interest expense.  The adjustment to gross                  
             income that would be necessary is depicted in the                        
             computation set forth in the hypothetical discussed above.               
             It is similar to the adjustment that the parties made in                 
             computing the taxpayer's interest expense for 1986 as shown              
             in the appendix.                                                         
                  Moreover, petitioner's position that it is entitled to              
             allocate net interest expense under section 1.861-8(e)(2),               








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