Bowater, Inc. And Subsidiaries, Formerly Known as Bowater Holdings, Inc. v. Commissioner of Internal Revenue

WILLIAM A. NORRIS, Circuit Judge:

This appeal requires us to interpret a Treasury regulation that was in effect during the tax years 1979 and 1980. The Regulation provides in part: “[T]he aggregate of deductions for interest shall be considered related to all income producing activities and properties of the taxpayer and, thus, allocable to all the gross income which the income producing activities and properties of the taxpayer generate.” 26 C.F.R. § 1.861-8(e)(2)(ii) (1978). 2 In Dresser Ind., Inc. v. Commissioner, 92 T.C. 1276, 1286, 1989 WL 64601 (1989), the Tax Court interpreted the…