Anschutz Company and Subsidiaries - Page 44

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          violating Congress’s “intent of harmony between the two Code                
          sections.”  Respondent is presumably focusing on the language of            
          the Senate report that “in order to more accurately reflect                 
          income and make the income tax system more neutral, a single,               
          comprehensive set of rules should govern the capitalization of              
          costs of producing, acquiring, and holding property”.  S. Rept.             
          99-313, supra at 140, 1986-3 C.B. (Vol. 3) at 140.  This argument           
          is unpersuasive.  As found above, the rules for the first level             
          allocations under both sections 1.263A-1(e)(3)(i) and 1.451-                
          3(d)(6)(ii), Income Tax Regs., are identical, requiring only that           
          a “reasonable allocation” be made.  The two sections can be                 
          applied simultaneously and will end with the same result under              
          the first level allocation, regardless of which section the                 
          taxpayer focuses on.                                                        
               Accordingly, we find that the legislative history does not             
          support incorporating the reasonableness standard of section                
          1.263A-1(f)(4), Income Tax Regs., into the first level                      
          allocations under sections 1.263A-1(e)(3)(i) and 1.451-                     
          3(d)(6)(ii), Income Tax Regs.                                               
               D. The Ordinary Meaning of Reasonable                                  
               Where a term is not defined in a statute, it should be given           
          its ordinary meaning.  Crane v. Commissioner, 331 U.S. 1, 6                 
          (1947); Keene v. Commissioner, 121 T.C. 8, 14 (2003); De Cou v.             
          Commissioner, 103 T.C. 80, 87 (1994); Goodson-Todman Enters.,               






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