Square D Co Subsidi v. CIR

In the United States Court of Appeals For the Seventh Circuit ____________ No. 04-4302 SQUARE D COMPANY AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF THE INTERNAL REVENUE SERVICE, Respondent-Appellee. ____________ Appeal from an Order of the United States Tax Court. No. 6067-97 ____________ ARGUED OCTOBER 25, 2005—DECIDED FEBRUARY 13, 2006 ____________ Before COFFEY, MANION, and KANNE, Circuit Judges. MANION, Circuit Judge. Square D Company attempted to take deductions for certain interest payments to its French parent that accrued in 1991 and 1992. Relying on Treasury Regulation…