American Air Liquide, Inc. and Subsidiaries - Page 14

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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.                              
                                             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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