MARKEY, Chief Judge.
The importer, Michelin Tire Corporation (Michelin) challenged a Treasury Department decision to assess countervailing duties against X-radial steel belted tires manufactured by Michelin Tire Manufacturing Company of Canada, Ltd. (Michelin of Canada).
The Government here seeks writs of mandamus and prohibition, (1) requiring the Customs Court to limit its review of the decision to the administrative record and (2) prohibiting the conduct...
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