FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $33,993 and $1,450 in petitioner's Federal income tax for 1974 and 1975, respectively. Other issues having been resolved by the agreement of the parties, the only one remaining for decision is whether petitioner, a national bank, may include loans outstanding to its wholly owned subsidiary, a mortgage company, at the ends of the years before the Court in its loan base for purposes of computing...
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