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ha[ve] been and will likely continue to be the basic mode ofproving foreign law." Universe Sales Co. v. Silver Castle, Ltd., 182 F.3d 1036, 1038 (9th Cir. 1999) (citing 9 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure: Civil, sec. 2444 (2d ed. 1995)). 2Rule 146 is taken almost verbatim from Fed. R. Civ. P. 44.1. See Note to Rule 146, 60 T.C. 1137. The rules are functionally identical. See Abdel-Fattah v. Commissioner, 134 T.C. 190, 194-195 (2010); PNC Fin. Servs. Grp., In

a[ve] been and will likely continue to be the basic mode of proving foreign law.” Universe Sales Co. v. Silver Castle, Ltd., 182 F.3d 1036, 1038 (9th Cir. 1999) (citing 9 Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure: Civil, sec. 2444 (2d ed. 1995)). While the parties’ experts disagree on how the French Government over time has characterized CSG and CRDS, this is a difference of opinion among experts on the content, applicability, and interpretation of foreign law. This

"Although a c may consider any materials presented on foreign law., the t judge is free 'to give them whatever probative valuë he ti they deserve.'" Chadwick v. Arabian American Oil Cö., sus 861 (quoting 9 Wright & Miller, Federal Practice and Proce sec. 2444, at 406 (1971)). The Court discussed the probat value of the affidavit there at issue. Chadwick v.;Arabia American Oil Co., supra at 861. We already have held that fir.st Nazer letter is admitted under Rule 146. Dis¼ussion weight we will gi