- 14 - under section 448(d)(2), thus subject to a flat 35-percent tax rate under section 11(b)(2). In reaching our holdings, we have considered all arguments and contentions made, and, to the extent not mentioned above, we conclude that they are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14Last modified: November 10, 2007