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FIRST WISCONSIN BANKSHARES CORP. v. UNITED STATES

Nos. 71-C-328, 71-C-329.

369 F.Supp. 1034 (1973)

FIRST WISCONSIN BANKSHARES CORPORATION, Plaintiff, v. UNITED STATES of America, Defendant (two cases).

United States District Court, E. D. Wisconsin.

December 18, 1973.

Attorney(s) appearing for the Case

Foley & Lardner by James P. Brody, Joseph R. Barnett, David Slook, Milwaukee, Wis., for plaintiff.

Thomas R. Jones, Justice Dept., Washington, D. C., David B. Bukey, U. S. Atty., Milwaukee, Wis., for defendant.

DECISION

MYRON L. GORDON, District Judge.

These are consolidated actions for the recovery of corporate income taxes. The taxpayer claims that various adjustments which were made to its taxable income for the years 1962 through 1965 were erroneous and illegal. Three issues are before me:

Issue I. Whether, for the purpose of calculating the bad debt reserve of the taxpayer's affiliated banks, certain "interim construction" loans made to

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