Rehearing and Rehearing En Banc Denied June 9, 1981.
WISDOM, Senior Circuit Judge.
The issue on this appeal is whether the petitioner, Hillsboro National Bank, realized income under the tax benefit rule when state personal property taxes it had paid on behalf of its stockholders and deducted from its income for federal income tax purposes in 1972 were refunded directly to the stockholders in 1973. We hold that the refunds were income to the Bank, and we affirm...
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