This case is certainly an indication that field agents are looking deeper into a taxpayer's application of simplified methods when it comes to allocating
uniform capitalization costs.
supportive expenses to a class of gross income narrower than all gross income, a more favorable apportionment may be achieved for FTC limitation purposes.
The proposed regulations do not address whether a taxpayer's method of allocating
costs constitutes a method of accounting.
The regulations contain no examples of allocating
capital gain under a power to adjust.
Triarc said it had also been advised that although this is one permissible method of allocating
tax basis, it may not be the only possible way to allocate tax basis.
In its defense, the taxpayer argued that because it had not yet incurred storage and handling costs for this merchandise (the taxpayer properly allocated freight costs), allocating
such costs would have been a distortion, violating the clear-reflection-of-income doctrine.
R&D expenses also qualify for the "sub-grouping" allocating
rules described above.
The property's basis would be treated as equal to its FMV at contribution for the purpose of allocating
items to the noncontributing partners.
This article illustrates one such technique: A detailed model for allocating
tolerable misstatement is presented and other applications are suggested.
Reciprocal agreements: Before allocating
income to a particular nonresident state, taxpayers should check whether that state has a reciprocal exemption agreement with their resident state.
Rather, it said section 482's effectiveness in allocating
income and expense items when foreign corporations are involved would be undermined significantly if section 881 required actual payment.
City of Emeryville--The Waste Board approved allocating
$25,000 to have rubberized mats installed under and around playground equipment at Stanford Avenue Park using approximately 3,000 waste tires.