- 68 - abused his discretion and may not change Qwest’s incremental cost allocation method to an average cost allocation method under section 446(b). V. Conclusion Petitioners have met their burden of proving that Qwest’s incremental cost allocation method is a reasonable allocation method for purposes of sections 1.263A-1(e)(3)(i) and 1.451- 3(d)(6)(ii), Income Tax Regs. Additionally, respondent’s determination that Qwest’s incremental cost allocation method failed to clearly reflect income was an abuse of discretion, and thus respondent may not change Qwest’s method to an average cost method. In reaching our holdings, we have considered all arguments and contentions made, and, to the extent not mentioned, we conclude that they are moot, irrelevant, or without merit. To reflect the foregoing and the concessions of the parties, Decision will be entered under Rule 155.Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68
Last modified: May 25, 2011