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2. Authority To Interpret the Award
The award results from the decision of the tribunal, which
came into being and obtained jurisdiction from the arbitration
agreement. Pursuant to the Convention, the United States must
recognize the award as binding and make its courts available for
enforcement of the award. See Article II of the Convention;
21 U.S.T. 2519. We are not, however, considering an action to
enforce the award, nor are we, in any way, determining the rights
of the parties to the award inter se. This is a proceeding to
redetermine an income tax deficiency, and, with respect to the
award, our inquiry is limited to the meaning of certain words
petitioner claims are ambiguous. The Convention neither
precludes our inquiry into whether the award is ambiguous, nor,
if we find it to be ambiguous, from interpreting it. Respondent
has advanced no reason other than the Convention as to why we
should refrain from considering whether the award is ambiguous;
since we are not persuaded by respondent’s Convention argument,
we shall consider whether the award is ambiguous.
3. The Award Is Ambiguous
The tribunal awarded Aminoil $179,750,764, an amount that
the tribunal reached by a process of calculation. The majority
of the award sets forth the premises and reasoning of the
tribunal leading to that calculation. We shall consider those
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