Memorandum Opinion
SWIFT, Judge:
Respondent determined deficiencies in the consolidated Federal income tax liability of petitioner Fourth Financial Corporation ("Fourth Financial") and its 99.8-percent owned subsidiary, Fourth National Bank and Trust Company, (Fourth National Bank), for the year 1979 in the amount of $267,845. Respondent's motion to amend its answer was granted by the Court on January 10, 1984. In the amended answer, the amount of the deficiency...
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