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FIRST SECURITY BANK OF UTAH, N. A. v. C. I. R.

Nos. 611-69, 612-69 and 613-69.

436 F.2d 1192 (1971)

FIRST SECURITY BANK OF UTAH, N. A., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. FIRST SECURITY BANK OF IDAHO, N. A., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. FIRST SECURITY COMPANY, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Tenth Circuit.

January 21, 1971.

Attorney(s) appearing for the Case

Stephen H. Anderson, Washington, D. C. (C. Preston Allen and Alonzo W. Watson, Jr., of Ray, Quinney & Nebeker, Salt Lake City, Utah, on the brief) for First Security Bank of Utah, N. A., and First Security Co.

John Brown, Washington, D. C. (Johnnie M. Walters, Asst. Atty. Gen., and Lee A. Jackson, Harry Baum and Stuart A. Smith, Attys., Dept. of Justice, on the brief) for Commissioner of Internal Revenue.

Before BREITENSTEIN and SETH, Circuit Judges, and TEMPLAR, District Judge.

BREITENSTEIN, Circuit Judge.

These consolidated appeals from the Tax Court relate to the allocation of income among taxpayers. No. 611-69 is an appeal by First Security Bank of Utah, N. A., (Utah Bank) from the decision that for the years 1955 to 1959 inclusive there is a deficiency in income taxes due from the taxpayer in the amount of $187,863.92. No. 612-69 is an appeal by First Security Bank of Idaho, N. A., (Idaho Bank...

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