Anschutz Company and Subsidiaries - Page 23

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          endlinks, was allocated to the IRU agreement, and if any retained           
          conduit was installed, the incremental cost of adding such                  
          conduit was allocated to Qwest’s retained assets.  Finally, Qwest           
          allocated cable material, splicing, and testing costs between the           
          IRU agreement and its retained assets based on the ratio of                 
          fibers sold to WorldCom to fibers retained by Qwest.   As an                
          example, in the Dallas-Houston IRU project, Qwest installed a 72-           
          fiber fiberoptic cable, and WorldCom had an IRU in 24 of those.             
          Qwest allocated 24/72ths of the costs of cable material, splicing           
          and testing to the IRU agreement and 48/72ths to Qwest’s retained           
          assets.                                                                     
          V.   Tax Returns for the Years in Issue                                     
               Petitioners timely filed consolidated Federal income tax               
          returns for the years in issue.                                             
               On February 4, 2003, respondent mailed a notice of                     
          deficiency to petitioners for the years in issue.  As reflected             
          in the notice of deficiency, respondent determined that an                  
          average cost allocation approach should be used for all of                  
          petitioners’ conduit installation and fiber pulling projects.  In           
          the notice of deficiency, respondent explained:                             
               certain incremental costs included in your cost of                     
               sales claimed on your tax returns for taxable years                    
               ending 7-31-94, 7-31-95 and 7-31-96 in the amounts of                  
               $20,149,787, $10,977,427 and $14,602,442, respectively,                

                    15(...continued)                                                  
          conduit, and the right-of-way costs to Qwest’s retained assets.             





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