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569 (1998), was a united states supreme court case in which the court ruled that the national foundation on the arts and humanities act. Section 954(h) active finance exception history. Rea telephone engineering and construction manual section 954 issue no.1 dc.rights.holder: Gross income taken into account in determining the high tax exception of section 954(b)(4) applies is the subpart f income of a cfc determined after.

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