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exhibits contain correspondence on the Department of the Treasury
letterhead, and correspondence to the Department of the Treasury.
Taken together, and viewed in the light most favorable to
petitioner, we are unable to conclude that they represent
anything more than confirmation that the Department of the
Treasury was considering whether to extend look-through treatment
to domestic subsidiaries with foreign parents.
Accordingly,
An appropriate order will be
entered granting respondent’s
motion for summary judgment and
denying petitioner’s motion for
summary judgment. Decision will be
entered for respondent.
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Last modified: May 25, 2011