OPINION
KASHIWA, Judge:
This income tax case comes before the court on the parties' stipulation of facts. Plaintiff, AMF Incorporated (AMF), seeks a refund for taxes and interest paid for its 1965 and 1966 tax years. At issue is the interpretation of the regulations promulgated under I.R.C. § 963. We must decide whether plaintiff was correct in applying the special rules of Treas.Reg. § 1.963-4 in determining the amount of its foreign tax credit...
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