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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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