Spartan Corporation, a U.S. company, manufactures widgets for sale in the United States and Europe. All manufacturing activities take place in the United States. During the current year, Spartan sold 100,000 widgets to European customers at a price of $5 each. Each widget costs $2 to produce. All of Spartan's production assets are located in the United States. For each independent scenario, determine the source of the gross profit from sale of the widgets using the 50/50 method.

A. Spartan ships its widgets F.O.B., place of destination.

B. Spartan ships its widgets F.O.B., place of shipment.

Cite the Internal Revenue Code and/or other authorities in support of your response