- 96 - 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.Page: Previous 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96
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