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FIRST CHICAGO CORP. v. COMMISSIONER

Docket No. 31175-88.

69 T.C.M. 2089 (1995)

T.C. Memo. 1995-109

First Chicago Corporation and Affiliated Corporations v. Commissioner.

United States Tax Court.

Filed March 20, 1995.

Attorney(s) appearing for the Case

John L. Snyder, Michael M. Conway, and Marilyn D. Franson, Three First Natl. Plaza, Chicago, Ill., for the petitioner. William G. Merkle, Dana Hundrieser, and James S. Stanis, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined deficiencies in petitioner's 1984 and 1985 income tax in the amounts of $2,371,664 and $21,828,460, respectively. Separate trials were ordered for the domestic and foreign issues. The issues under consideration here concern petitioner's 1984 acquisition of a 44.5-percent interest in a Brazilian banking institution for $14.6 million. The investment was ultimately unsuccessful, and...

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