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FIRST NAT. BANK OF SOUTH CAROLINA v. UNITED STATES

Civ. A. No. 74-1591.

413 F.Supp. 1107 (1976)

FIRST NATIONAL BANK OF SOUTH CAROLINA, Plaintiff, v. UNITED STATES of America, Defendant.

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

April 6, 1976.

Attorney(s) appearing for the Case

Charles W. Knowlton and J. Donald Dial, Jr., Boyd, Knowlton, Tate & Finlay, Columbia, S. C., for plaintiff.

Glen E. Craig, Asst. U. S. Atty., Columbia, S. C., and John A. Townsend, Tax Div., Dept. of Justice, Washington, D. C., for defendant.

ORDER

HEMPHILL, District Judge.

Plaintiff-taxpayer and the government have each moved for summary judgment in this action claiming refund of federal income taxes and brought pursuant to Section 7422 of the Internal Revenue Code of 1954, 26 U.S.C. § 7422. The sole question involved is the propriety of the IRS' disallowance of certain deductions by the bank during the 1968 tax year as ordinary and necessary business expenses within the meaning of Section...

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