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EGPC's tax credit prospectively. Petitioner believed it would
maximize its chances of obtaining such a change by demonstrating
to the Minister of Petroleum that the intent of the parties to
the MCA was for EGPC to get a tax deduction, instead of tax
credit.
In January 1992, lawyers for Amoco interviewed Craig, former
president of Amoco Egypt, and in February 1992, they interviewed
Leithy, former chairman of EGPC, with respect to their respective
understandings of the purpose and intent of Article IV(f)(6) as
written in 1975. They did not seek such information directly
from EGPC.
Between February 2 and February 6, 1992, Charles Pitman,
Amoco Egypt's incoming president, and Fuller, chairman of the
board of Amoco, discussed Amoco's foreign tax credit controversy
with Dr. Hamdi El Banbi, the Minister of Petroleum and the former
chairman of GUPCO. The purpose of Fuller's presence was, inter
alia, to "underscore the seriousness of the dispute" with the
IRS.
On February 6, 1992, David Work, the outgoing president of
Amoco Egypt, Pitman, Lenahan, and Chiati met with Banbi
concerning petitioner's dispute with the IRS. Lenahan told Banbi
that other U.S. oil companies were interested in the case and
that Amoco was taking the lead. Banbi agreed to help Amoco if he
could do so at no cost to the ARE and suggested that Amoco advise
EGPC's chairman Dr. Moustafa Shaarawy. Shortly after the
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