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Office of Chief Counsel Internal Revenue Service Memorandum Number 201642033 Release Date 10/14/2016 CC INTL B03 RLChewning POSTN-126657-16 UILC date to from subject 199. In calculating QPAI DPGR is reduced by CGS and the related other expenses losses and deductions. In determining CGS allocable to DPGR for purposes of section 199 c 1 B i Treas. Reg. 1. The taxpayer then allocated its CGS between DPGR and non-DPGR in accordance with Treas. Reg. 1. 199-4 b 2 e.g. if 100 of the gross receipts...

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