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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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