IDAHO FIRST NATIONAL BANK AND ITS SUBSIDIARIES v. COMMISSIONER

Docket Nos. 27381-88, 27382-88.

66 T.C.M. 1364 (1993)

T.C. Memo. 1993-539

Idaho First National Bank and Its Subsidiaries v. Commissioner. Moore Financial Group, Inc. and Its Subsidiaries v. Commissioner.

United States Tax Court.

Filed November 18, 1993.


Attorney(s) appearing for the Case

Robert J. Jones, L. Hope O'Keeffe, Steven P. Lockman, 1200 New Hampshire Ave., NW., Washington, D.C., for the petitioners. Wilton A. Baker, for the respondent.


Supplemental Memorandum Findings of Fact and Opinion

COHEN, Judge:

In our prior opinion, 95 T.C. 185 (1990), we held that the losses incurred by Moore Financial Group, Inc., in disposing of assets of an insolvent bank acquired through Federal Deposit Insurance Corporation (FDIC) bidding processes, were not "built-in deductions" within the meaning of section 1.1502-15(a)(2), Income Tax Regs. Our conclusion in this regard was...

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