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PACIFIC FIRST FEDERAL SAVINGS v. COMMISSIONER

Docket No. 27606-87.

94 T.C. 101 (1990)

PACIFIC FIRST FEDERAL SAVINGS BANK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 27, 1990.

Attorney(s) appearing for the Case

Alan S. Kaden and John F. Coverdale, for the petitioner.

Fera Wagner and Richard Osborne, for the respondent.

OPINION

WELLS, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:


  Year                                        Deficiency
  1978 ....................................   $1,743,066
  1979 ....................................    5,057,885
  1980 ....................................    2,512,321

After concessions, the issue presented...

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