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CHELTENHAM FEDERAL SAVINGS AND LOAN ASS'N v. COMMISSIONER

Docket No. 3912-90.

69 T.C.M. 2317 (1995)

T.C. Memo. 1995-149

Cheltenham Federal Savings and Loan Association, n.k.a. Prime Savings Bank, fsb v. Commissioner.

United States Tax Court.

Filed April 4, 1995.

Attorney(s) appearing for the Case

Zachary P. Alexander and William S. Pilling III, 2600 One Commerce Square, Philadelphia, Pa., for the petitioner.

Paul J. Sude and Lisa Primavera-Femia, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:1

This case is before us on petitioner's motion for summary judgment and respondent's cross-motion for summary judgment. Rule 121.2 The sole issue is whether section 1.593-6A(b)(5)(vi) and (vii), Income Tax Regs., is valid to the extent that it requires petitioner, in using the "percentage of taxable income method...

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