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TRUSTMARK CORPORATION AND SUBSIDIARIES v. COMMISSIONER

Docket No. 18372-89.

67 T.C.M. 2764 (1994)

T.C. Memo. 1994-184

Trustmark Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed April 28, 1994.

Attorney(s) appearing for the Case

Louis G. Fuller, John R. Hutcherson, George P. Hewes III, 248 E. Capital St., P.O. Drawer 119, Jackson, Miss., Paul B. Eason, Philip C. Cook, Timothy J. Peaden, Terence J. Greene, and Sidney O. Smith, Jr., for the petitioner. Albert L. Sandlin, Jr., Gary F. Walker, and Clinton M. Fried, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

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

Tax Year Ended                      Deficiency

12/31/73 ........................    $ 24,423
12/31/74 ........................     518,184

In August 1983, Trustmark National Bank entered into an agreement to purchase the assets...

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