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HONGKONG & SHANGHAI BANKING CORP. v. COMMISSIONER

Docket No. 4075-80.

85 T.C. 701 (1985)

THE HONGKONG AND SHANGHAI BANKING CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 5, 1985.

Attorney(s) appearing for the Case

Paul A. Teschner, for the petitioner.

Thomas C. Borders and Andrew P. Fradkin, for the respondent.

OPINION

NIMS, Judge:

This matter is before the Court on respondent's motion for an order under section 7456(b)1 to require petitioner to produce in Court certain books and records located in its home office in Hong Kong. Respondent determined deficiencies in petitioner's Federal income tax as follows:

Year ended Dec. 31—                       Deficiency...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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