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page in Joint Exhibit 692-ZN(23), setting forth (1) the “withholding
tax imposed”, (2) the “40-percent pecuniary benefit” the Central
Bank received, and (3) the purported “balance (60 percent) of actual
withholding tax paid” by the Central Bank, on its September 1985
phase II CGA, tranche I interest payments to petitioner and other
foreign lenders, is contained infra in appendix B. (The information
from this schedule page concerning the Central Bank’s September 27,
1985, phase II CGA, tranche I net interest remittance of $17,441.66
(U.S.) to petitioner, is discussed in our findings.) Indeed, (1)
the Morgan Bank letter dated January 21, 1986 (Joint Exhibit 694-
ZP(6), pertinent portions of which are quoted in our findings), and
(2) petitioner’s own “comptroller’s memorandum” dated February 20,
1986 (Joint Exhibit 695-ZQ(4), pertinent portions of which are
quoted in our findings), reflect that these Central Bank schedule
pages enclosed in Mr. Oliveira’s November 19, 1985, letter, covered
phase II CGA, tranche I through tranche VII interest payments for
the period from “June 28, 1985 to September 27, 1985". The Morgan
Bank letter and the comptroller’s memorandum each further confirm
that the Central Bank had reported “receiving” a “40-percent
pecuniary benefit” in connection with its purported withholding tax
payments on those September 27, 1985, phase II CGA interest
payments.
Although Joint Exhibit 697-ZS (which summarizes and lists the
related DARF’s and other documents issued in connection with the
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