2.USAco, a domestic corporation, owns all of the stock of FSub, a foreign corporation. FSub manufactures widgets and sells them at a price of $100 to USAco, which then resells the widgets to U.S. customers. USAcos 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?