Anschutz Company and Subsidiaries - Page 43

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          patterned after the regulations under section 451, taking a                 
          “similarly liberal approach”.  See S. Rept. 99-313, supra at 141,           
          1986-3 C.B. (Vol. 3) at 141; H. Rept. 99-426, supra at 626, 1986-           
          3 C.B. (Vol. 2) at 626.  Respondent argues that consequently, the           
          definitions of section 1.263A-1(f)(4), Income Tax Regs., “and the           
          principles of its detailed guidance for the allocation of costs             
          should govern * * * the interpretation of ‘reasonable method’               
          under the section 451 regulations.”  We interpret the legislative           
          history differently.                                                        
               The Senate report does not state that the regulations under            
          sections 263A and 451 should be identical.  Nor does the Senate             
          report state that the same rules should apply to allocations                
          under the two sections.  The Senate report provides only that the           
          uniform capitalization rules be “patterned” after the section 451           
          regulations, and it explicitly acknowledges that changes may be             
          needed “in order to adapt such rules to production not involving            
          a [long-term] contract”.  The Senate report suggests that                   
          Congress knew differences existed between allocations under                 
          sections 263A and 451, and thus different rules would be                    
          required.                                                                   
               Respondent further contends that, by not incorporating the             
          reasonableness standard of the section 263A regulations into the            
          section 451 regulations, the “choice” of which Code section to              
          apply first “will lead to radically different results,” thus                






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