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               Petitioners contend that the supermajority voting                      
          requirements in the articles of incorporation meant little                  
          because the laws of most U.S. States require that, to change the            
          number of authorized shares or to sell assets other than in the             
          usual course of business, an 80-percent majority of shareholders            
          must approve.  Petitioners also contend that the veto powers                
          differ little from statutory restrictions on domestic corporate             
          boards provided by the Model Business Corporation Act (MBCA).  We           
          disagree.  Petitioners cite no State laws or MBCA provisions that           
          give 25-percent shareholders the veto powers present in these               
          cases.  The 1973 basic agreement, which created the veto powers             
          that were in effect in 1992, states that the agreement shall be             
          construed under Japanese law.  Petitioners have not shown whether           
          State law or MBCA provisions are similar to Japanese law.                   
               Petitioners point out that dividends were more important to            
          Furukawa and Sumitomo than to Burndy-US because Burndy-US                   
          received royalties and management fees.  However, the agreements            
          between Burndy-Japan shareholders relating to management fees and           
          royalties expired after 5 years.  Burndy-US had no guaranty that            
          the management fees and royalties would continue; thus, its need            
          for dividends could increase.  Burndy-US’s receipt of royalties             
          and management fees does not show that Burndy-US controlled                 
          Burndy-Japan.                                                               
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