CONTIE, Circuit Judge.
The Commissioner appeals from a decision of the United States Tax Court in favor of National-Standard Company on National-Standard's petition for redetermination of a federal income tax deficiency assessed by the Commissioner. We have jurisdiction pursuant to 26 U.S.C. § 7482. We affirm.
I.
On September 17, 1970, National-Standard entered into a loan agreement pursuant to which the company borrowed 250,000,000 Luxembourg...
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