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ARKANSAS BEST CORP. v. COMMISSIONER

Docket No. 18954-80.

83 T.C. 640 (1984)

ARKANSAS BEST CORPORATION AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 29, 1984.

Attorney(s) appearing for the Case

Vester T. Hughes, Jr., David F.P. O'Connor, Eric R. Cromartie, and Stephen D. Good, for the petitioner.

Raymond L. Collins and Rebecca W. Wolfe, for the respondent.

NIMS, Judge:

Respondent determined deficiencies in petitioner's Federal income tax as follows:

Year      Deficiency

1969       $20,224
1970        20,224
1971        50,560
1972     3,355,968
1973      $244,352
1974       230,519
1975       928,911
1976     2,077,163

After concessions, the issues presented for decision are (1) whether petitioner's loss on the sale of its controlling interest in a bank is ordinary...

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