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PEOPLES FEDERAL SAVINGS & LOAN ASS'N v. UNITED STATES

Civ. A. No. 69-897.

320 F.Supp. 179 (1970)

PEOPLES FEDERAL SAVINGS & LOAN ASSOCIATION, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. South Carolina, Florence Division.

December 7, 1970.

Attorney(s) appearing for the Case

W. Laurier O'Farrell, Willcox, Hardee, Houck, Palmer & O'Farrell, Florence, S. C., for plaintiff.

Johnnie M. Walters, Asst. Atty. Gen., Hubert M. Doster and Lawrence R. Jones, Jr., Attys., Dept. of Justice, Washington, D. C., and Joseph O. Rogers, Jr., U. S. Atty., and Wistar D. Stuckey, Asst. U. S. Atty., Columbia, S. C., for defendant.

FINDINGS OF FACT, CONCLUSIONS OF LAW, OPINION AND ORDER

DONALD RUSSELL, District Judge.

This action to recover allegedly improperly assessed and collected income taxes involves the proper application of Section 593 of the Internal Revenue Code of 1954 (26 U.S.C.) and the regulations issued thereunder, by which a domestic building and loan association organized for mutual purposes and without profit may, in lieu of taking a deduction of actual loan losses...

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