AM20014-001 (Dec. 13, 2013)

(IRS Chief Counsel Memo involving co-op advertising allowance (amount retailer receives from vendor for placement of advertisement of vendor's products in retailer's advertising flyer) and whether it is domestic production gross receipts for purposes of I.R.C. Sec. 199 deduction; IRS noted that determination is fact-dependent and determined on basis of whether allowance is advertising income from retailer's performance of advertising services for vendor and whether flyers qualify for advertising income exception of Treas. Reg. Sec. 1.199-(3)(I)(5)(ii)).