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involved herein. We are still left with questions stemming from
the fact that, whether or not authorized by Article IV(f)(6),
EGPC credited Amoco Egypt's income taxes paid by it against its
income taxes. These issues relate to the assertion by respondent
that such action on EGPC's part constituted a refund or subsidy
which should deprive Amoco Egypt of its claimed foreign tax
credit. Arguably, our disposition of these issues in favor of
petitioner could have obviated our lengthy analysis of the proper
interpretation of Article IV(f)(6). However, we decided to set
forth such analysis, not only because the parties extensively
argued the issue of such interpretation but because we concluded
that such analysis would provide useful background for resolution
of the issues that still remain. Moreover, we note that even
though the credit was not, at any time, proper under Article
IV(f)(6), EGPC's action in taking the credit for periods prior to
the period ending June 30, 1980, and the running of the period of
limitations would require us, to that extent, to deal with such
action as a separate matter. We now turn to the refund and
subsidy issues.
With respect to the existence of a refund, section 1.901-
2(e), Income Tax Regs., provides in pertinent part as follows:
(1) In general. Credit is allowed * * * for the
amount of income tax * * * that is paid to a foreign
country by the taxpayer. * * *
(2) Refunds and credits--(i) In general. An
amount is not tax paid to a foreign country to the
extent that it is reasonably certain that the amount
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