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FIRST NATIONAL BANK OF CHICAGO v. COMMISSIONER

Docket No. 3408-72.

64 T.C. 1001 (1975)

THE FIRST NATIONAL BANK OF CHICAGO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 3, 1975.

Attorney(s) appearing for the Case

William P. Sutter and Donna Rankin, for the petitioner.

Seymour I. Sherman, for the respondent.

FAY, Judge:

Respondent determined a deficiency of $419,253.17 in the Federal income tax of petitioner, the First National Bank of Chicago, for the year 1968. Certain concessions having been made, it remains for us to decide if respondent properly disallowed a portion of the deduction claimed by petitioner for an addition to its reserve for bad debts. Sec. 166(c), I.R.C. 1954.1

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