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untrustworthy and were concocted to substantiate legerdemain; i.e.,
they were devised to portray the appearance of the fictitious
payments of taxes. Accordingly, we find that the group DARF’s do
not constitute direct or secondary evidence that the Central Bank
paid withholding taxes on petitioner’s behalf. Moreover, we find
nothing else in the record that constitutes credible direct or
secondary evidence that the purported withholding tax payments were
in fact made. Consequently, we hold that petitioner is not entitled
to foreign tax credits, during 1984 through 1986, under section 901
for the purported withholding tax payments by the Central Bank on
its restructuring debt interest remittances to petitioner. See sec.
905(b).
Issue 2. The Subsidy/Pecuniary Benefit Issue
In light of our holding on the payment issue, we need not reach
the issue of whether the Central Bank’s purported “withholding tax
payments” on petitioner’s behalf (that are potentially creditable
to petitioner) must be reduced by the amount of any pre-June 28,
1985, pecuniary benefit the Central Bank may have received and
whether that benefit constitutes an indirect subsidy under section
1.901-2(e)(3)(ii), Income Tax Regs. Compare Continental Ill. Corp.
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