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BANK OF AMERICA NATIONAL TRUST & SAVINGS ASS'N v. COMMISSIONER

Docket No. 3568-71.

61 T.C. 752 (1974)

BANK OF AMERICA NATIONAL TRUST AND SAVINGS ASSOCIATION, A NATIONAL BANKING ASSOCIATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 18, 1974.

Attorney(s) appearing for the Case

Harry R. Horrow and Stephen J. Martin, for the petitioner.

Vernon R. Balmes, for the respondent.

TANNENWALD, Judge:

Respondent has determined the following deficiencies in petitioner's Federal income taxes:

Year                                              Deficiency

1965 -----------------------------------------  $1,202,390.96
1966 -----------------------------------------   1,245,141.15

There are two questions presented for decision:

(1) Whether petitioner is...

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