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satisfied that the lack of current customer addresses would have
represented a "clear proximate danger" to petitioner's business.
Petitioner has also satisfied us that its "ultimate purpose"
in paying the expenses in question was to "protect or promote" its
delivery service from the United States to Guatemala, rather than
to benefit the Guatemalan companies. Although the disputed
expenses related to the deliveries of packages from Guatemala to
the United States which was the business of the Guatemalan
companies, petitioner derived a substantial benefit not otherwise
available through the insertion of advertisements and other
materials of its business into the envelopes originating from
Guatemala. The "stuffing" of these materials had a direct nexus
with petitioner's U.S.-Guatemala delivery business--the materials
provided targeted potential customers with instructions on sending
envelopes and small packages from the United States to Guatemala.
A large percentage of petitioner's revenues for the year in issue
came as a result of the flow of envelopes originating in Guatemala.
It cannot be overemphasized that the promotional and marketing
process was the centerpiece of petitioner's business. Thus, we
conclude that there was a direct nexus between the payment of the
expenses in dispute and petitioner's outbound delivery business.
In applying the second prong of the Lohrke test, we are
satisfied that the expenses in dispute were appropriate in
promoting petitioner's business. Petitioner did not specifically
deduct "inbound expenses"--the expenses in dispute. Rather,
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