Citron Corporation has some domestic production gross receipts (DPGR) that qualify for the DPAD and some that do not.
a. Is there a safe harbor that allows non-DPGR to be included in DPGR?
b. Would Citron ever want to treat DPGR as non-DPGR? Why or why not?
c. Continuing with part (b), when can this strategy be done?