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RIGGS NATIONAL CORPORATION & SUBSIDIARIES v. COMMISSIONER

Docket No. 24368-89.

81 T.C.M. 1023 (2001)

T.C. Memo. 2001-12

Riggs National Corporation & Subsidiaries, f/k/a Riggs National Bank and Subsidiaries v. Commissioner.

United States Tax Court.

Filed January 22, 2001.

Attorney(s) appearing for the Case

Joel V. Williamson, Thomas C. Durham, Kim M. Boylan, Charles W. Hall, and Stephen M. Feldhaus, for the petitioner.

Theodore J. Kletnick, William G. Merkle, Rebecca I. Rosenberg, and Robert T. Bennett, for the respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

This case is before us on remand from the Court of Appeals for the District of Columbia Circuit. See Riggs Natl. Corp. & Subs. v. Commissioner [99-1 USTC ¶ 50,185], 163 F.3d 1363 (D.C. Cir. 1999), revg. and remanding [Dec. 51,683] 107 T.C. 301 (1996).

The crux of the dispute involves petitioner's entitlement...

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