Sentence: see id.  275(a)(4) (""no deduction shall be allowed for the following taxes: . . . excess profits taxes imposed by the authority of any foreign country . . . if the taxpayer chooses to take to any extent the benefits of [] 901.""); 26 c.f.r.  1.901-1(h)(2) (""taxpayers who are denied the credit for taxes for particular taxable years are the following: . . . [a] taxpayer who elects to  deduct taxes paid or accrued to any foreign country . . . [pursuant to sections] 164 and 275."").