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BANC ONE CORP. v. COMMISSIONER

Docket No. 10756-80.

84 T.C. 476 (1985)

BANC ONE CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 28, 1985.

Attorney(s) appearing for the Case

Charles J. Kegler, Paul D. Ritter, Jr., and Edward C. Hertenstein, for the petitioner.

Eugene P. Bogner, for the respondent.

COHEN, Judge:

Respondent determined deficiencies in petitioner's income tax liability of $455,263 for the tax year ended 1974 and $967,265 for the tax year ended 1975. The issues for decision are as follows: (1) Whether petitioner should be allowed depreciation deductions under section 1671 with respect to either loan or deposit premiums allegedly acquired in the purchase of two banks, and (2) whether petitioner properly allocated...

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