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renounced any assertion of conspiracy or like characterization in
respect of the action of the ETD in 1992 and has confined her
assertions to "orchestration" of such action by petitioner and
Amoco Egypt and less than full disclosure of facts to respondent
in connection with petitioner's requests for rulings. Our review
of the record has satisfied us that respondent's charges and
innuendos are without merit and that the actions of petitioner,
Amoco Egypt, and their counsel represent simply efforts, expended
with skill and professional competence and propriety, to cope
with a troublesome situation. In any event, such activities
neither help nor hinder the accomplishment of the task before us
(namely to reach our own conclusions as to the issues involved),
except to the extent that such activities should properly be
taken into account in determining the intent of the parties.
Under these circumstances, we will make no further comment on the
above-described assertions of respondent.
The initial dispute between the parties involves the
question whether, under Egyptian law, EGPC was entitled to claim
a credit against its income taxes for the payments made on
account of Amoco Egypt's income taxes. Respondent asserts that
Article IV(f)(6) of the MCA unambiguously provides for such a
credit, that the Arabic version of the MCA has the force of law
so that there is no room for interpretation to take into account
the intent of the parties to the MCA, and that, in any event, the
parties to the MCA intended that EGPC would be entitled to such a
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