Claymont Investments, Inc., As Successor in Interest to New CCI, Inc. and Subsidiaries - Page 25

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          Holdings, a nonmember, followed by a new loan from Holdings to              
          CIHI.  Because there was an intercompany transaction between CIC            
          and CIHI, pursuant to section 1.1502-13(b)(1)(i), Income Tax                
          Regs., petitioners were entitled to the deferral of foreign                 
          exchange gain.                                                              
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             under Rule 155.                          

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