Sunoco, Inc. and Subsidiaries v. Commissioner

118 T.C. No. 11

UNITED STATES TAX COURT SUNOCO, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19631-97. Filed March 15, 2002. P claimed foreign tax credits under sec. 901(a), I.R.C., on its consolidated returns for 1982, 1983, 1984, and 1986. In these proceedings, P seeks to change the method of computing the overall limitation on the credit imposed by sec. 904(a), I.R.C. Specifically, P seeks to change the manner in which it allocates and apportions interest expenses for purposes of computing taxable income from sources without the United States,…