Court of Appeals for the Third Circuit June 24, 1996, 95-7253 (Tate & Lyle, Inc. And Subsidiaries v. Commissioner of Internal Revenue Service)

OPINION OF THE COURT

MANSMANN, Circuit Judge.

In this appeal, the Commissioner has asked us to review a ruling which allowed a

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United States taxpayer to deduct interest owed to a related foreign payee when it was accrued rather than paid. Specifically, we must determine whether the United States Tax Court erred in holding that Treas. Reg. § 1.