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COMMERCIAL SECURITY BANK v. COMMISSIONER

Docket No. 5652-79.

77 T.C. 145 (1981)

COMMERCIAL SECURITY BANK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 29, 1981.

Attorney(s) appearing for the Case

John S. Nolan, for the petitioner.

Robert N. Armen, for the respondent.

OPINION

TANNENWALD, Chief Judge:

Respondent determined deficiencies in the Federal income taxes of Orem State Bank (Orem) of $2,793.20 and $86,510.06 for the taxable years ending December 31, 1973, and June 14, 1974. Petitioner has accepted liability for all deficiencies adjudged against Orem as transferee of Orem's assets and liabilities. See sec. 6901 et seq.1 Because of concessions by petitioner, the issues remaining...

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