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created only to the extent such interest was received from the
foreign government. Petitioner seeks to draw some support for
its position herein by contending that such action shows that, at
the time of the 1958 amendments to section 904(c), Congress had
limited interest on deficiencies attributable to a foreign tax
credit. We do not agree. In the first place, no foreign tax
carryback was involved. Secondly, if any inference were to be
drawn from such action, it is that Congress assumed that interest
on deficiencies involving foreign tax credits would be imposed
and that limiting such interest was necessary in order to avoid
double payment of interest on taxes paid on the same income. See
H. Rept. 920, 81st Cong., 1st Sess. 3 (1948). It is a far cry to
say that the objective of avoiding double payment of interest
should be considered as blessing the position of petitioner
herein, that no interest should be paid at all.
Petitioner argues that Congress' enactment of section
6611(g) (now section 6611(f)(2)), prohibiting interest on an
overpayment, i.e., a refund, created by a carryback of foreign
taxes, makes significant the failure to amend section 6601(d) to
include such a carryback among the specified carrybacks which
were not to reduce an underpayment, i.e., a deficiency, for the
purpose of determining interest due. We decline to adopt
petitioner's position. As the Court of Appeals for the Federal
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