05 states that if a taxpayer receives a payment that is partly trade discount and partly cooperative advertising, the taxpayer may use the Advance Trade Discount Method "only with respect to the portion of the payment that is allocable
to the advance trade discount based on objective criteria" There is no mention of whether the obligation to repay is crucial in carving out part of the advance as cooperative advertising.
Taxpayers using either the section 861 method (16) or the simplified deduction method (17) to allocate costs may use the "Wage Expense Safe Harbor" to determine the amount of W-2 wages properly allocable
199 wage limitation amount includes only amounts that are properly allocable
If one accepts the proposition that there is a link between current production of hazardous waste (as a manufacturing by-product) and inventory, then disposal costs of current waste might be properly allocable
to inventory by reason of the performance of production activities.
According to the Tax Court, the issue was not whether the taxpayers' interest on their 1987 income tax deficiency was "personal" but, rather, whether it was "properly allocable
to a trade or business.
A foreign partner's allocable
share of partnership ECTI for the partnership's tax year is equal to that foreign partner's distributive share of partnership gross income and gain effectively connected and properly allocable
to the partner under Sec.
3) a ratable portion of other deductions not directly allocable
to DPGR or to another class of income.
At least one payment, allocable
, for property use during a calendar year, is to be paid after the close of the following calendar year.
Memo 1991-557, 11/7/91), the Tax Court held Black & Decker's worthless stock loss in a foreign subsidiary, claimed in a pre-TRA 86 taxable year, to be allocable
entirely against its foreign source income for purposes of determining its foreign tax credit limitation.
172 is the difference between the (1) NOL for the tax year and (2) NOL for the tax year without including deductions for interest on the portion of any debt allocable
to a CERT (i.