Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 96

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          subsidy provisions of the temporary and final regulations are               
          valid.  Norwest Corp. v. Commissioner, 69 F.3d at 1408-1410;                
          Continental Ill. Corp. v. Commissioner, 998 F.2d at 519-520; Nissho         
          Iwai Am. Corp. v. Commissioner, supra at 775-777.  In light of our          
          holdings on the legal liability and Central Bank issues (i.e., that         
          the "withholding tax" purportedly paid by the Central Bank on its           
          restructuring debt interest remittances to petitioner is not a              
          potentially creditable tax to petitioner), we need not reach the            
          issue of whether any pecuniary benefit the Central Bank received            
          represents an indirect subsidy for purposes of section 1.901-               
          2(e)(3)(ii), Income Tax Regs.  Compare the PeMex case with Amoco            
          Corp. v. Commissioner, T.C. Memo. 1996-159.                                 
               To reflect concessions by the parties,                                 

                                                  Decision will be entered            
                                             under Rule 155.                          




















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