- 23 - 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.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
Last modified: May 25, 2011