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February 6, 1992, meeting, Banbi told Work to let him know if
Amoco was not receiving full cooperation from EGPC. Amoco
contacted Shaarawy shortly after the February 6, 1992, meeting.
On February 10, 1992, Lenahan and Carlson met with EGPC's
A. Radwan. Lenahan and Carlson requested EGPC's help to show:
(1) That EGPC is part of the Egyptian Government, and (2) that
EGPC does not receive a subsidy from the Egyptian Government. On
February 11, 1992, Lenahan and Carlson met with A. Radwan again
and provided him with an extensive report on the two issues.
EGPC expressed that it would fully cooperate.
Amoco did not ask Minister Banbi to consider changing EGPC's
tax credit practice until May 13, 1992, after the determination
of the ETD, reflected in a letter dated May 2, 1992, that EGPC
was not entitled to claim credits for foreign partner taxes.
Until May 1992, EGPC had officially taken the position that it
was entitled to a tax credit.
In December 1989, Ahmed Ismail, a tax inspector in the
Petroleum Section of the Department of Tax on Joint Stock
Companies of the ETD, conducted his first audit of EGPC,
concerning its 1983-1984 return. He did not challenge EGPC's
claimed tax credits for royalties or foreign partner taxes. Such
action conformed with the failure to challenge such credits in
earlier years.
In an audit report signed November 29, 1990, concerning
EGPC's 1984-1985 tax year, Ismail reported that EGPC subtracted
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