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MIAMI NATIONAL BANK v. COMMISSIONER

Docket No. 580-74.

67 T.C. 793 (1977)

MIAMI NATIONAL BANK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 14, 1977.

Attorney(s) appearing for the Case

David Emanuel, for the petitioner.

Kevin A. Suffern and Alan Summers, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined the following deficiencies in the petitioner's corporate income taxes:

                FYE Apr. 30—                      Deficiency

                1970 .......................      $394,746.52
                1971 .......................       833,513.58

The parties have settled numerous issues; the only one remaining for decision is whether the petitioner...

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