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ZIONS FIRST NATIONAL BANK v. COMMISSIONER

Docket No. 386-72.

33 T.C.M. 941 (1974)

T.C. Memo. 1974-210

Zions First National Bank v. Commissioner.

United States Tax Court.

Filed August 13, 1974.

Attorney(s) appearing for the Case

J. Jay Bullock, 619 Kearns Bldg., Salt Lake City, Utah, for the petitioner. Ralph W. Jones, for the respondent.

Memorandum Opinion

FAY, Judge:

Respondent has determined a deficiency in petitioner's Federal income tax for the calendar year 1968 in the amount of $23,998.99.

This case was submitted with a full stipulation of facts under Rule 122 of the Tax Court Rules of Practice and Procedure.

The sole issue for our determination is whether respondent has abused the discretion vested in him by section 166(c) of the Internal Revenue Code of 1954,

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