- 24 -
losses are to be treated as interest expense under section 1.861-
8(e)(2), Income Tax Regs. Consequently, the exchange losses
related to swap losses should also be apportioned as interest
expense in accordance with our treatment of that item. See supra
pp. 12-18.
To take into account the concessions of the parties and our
disposition of the investment tax credit issue, see supra note 1,
Decision will be entered
under Rule 155.
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