business of finance.” Id. The Treasury Regulations take the view that money is fungible. Id. (citing Treas.Reg. 1.861-8(e)(2)(I) (as amended in 1988)). Given such fungibility, we appreciated that, in the normal business context, the amount and timing of business borrowing rarely, if ever, correlate to specific investments. Id. For example, a business may incur a debt in a single transaction, even though its cash requirements are spread out over the ensuing quarter. The business may then choose to reduce the cost of holding these as-yet unneeded funds by investing in short-term, interest-bearing instruments. Id. (citing Ideal Basic Indus. v. Commissioner, 82 T.C. 352, 400, 1984 WL 15542 (1984)); see also General Portland Cement Co. v. United States, 628 F.2d 321, 342-43 (5th Cir.1980) (<HOLDING>). In such a case, “the total cost of the
holding that the effects of the victims deaths upon the families is part of the circumstances of the crime and is properly presented to the jury at the penalty phase holding that the district court must make findings on the record as to the basis for its conclusion about the amount of actual loss holding corporations president personally liable where he had ultimate control over businesss daytoday operations and was the corporate officer principally in charge of directing employment practices holding that a district court must consider whether a foreign state so dominated the operations of the corporate entity that a principalagent relationship existed holding that the actual cost of borrowing was the amount properly allocable to mining operations so as not to allocate a disproportionate share of the businesss financing costs to a specific phase of its operations