USAco, a domestic corporation, owns all of the stock of FSubco, a foreign corporation. FSubco manufactures widgets and sells them at a price of $100 to USAco, which then resells the widgets to U.S. customers. USAcoâs gross receipts for the year are $200 million. Under what circumstances would USAco be potentially subject to the Code Sec. 6662(e) substantial valuation misstatement penalty?
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