RJR Nabisco Inc. (Formerly R.J. Reynolds Industries, Inc.) and Consolidated Subsidiaries - Page 10

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          cough syrup aired for between 4 and 8 years.  Portions of one               
          advertising execution may be used in later executions of the same           
          or different campaigns.  For example, E.F. Hutton ran                       
          advertisements in 1979, 1980, and 1982, that all contained the              
          line:  “When E.F. Hutton talks, people listen.”                             
               H.  Litigated Expenses                                                 
               The parties have identified a portion of the disallowed                
          deduction as the “litigated expenses” (litigated expenses).  The            
          parties wish us to decide the deductibility of the litigated                
          expenses.  They then will use our decision as a basis to settle             
          their disagreement with respect to the remaining disallowed                 
          deductions.  The litigated expenses total $1,804,029 and relate             
          to the product lines described in supra at section II.C.                    
          III.  Expropriation Issue                                                   
               A.  American Independent Oil Co.; Nature of the Dispute                
               During 1982, American Independent Oil Co. (Aminoil), a                 
          Delaware corporation, was a member of the affiliated group.                 
          Aminoil had been in the business of exploring for, producing,               
          refining, and selling crude oil and other natural resources                 
          outside of the United States.  From 1948 until 1977, Aminoil                
          enjoyed a concession to explore for and exploit oil, gas, and               
          other natural resources in an area on the frontier of Kuwait.  In           








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