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COLONIAL SAVINGS ASSOCIATION v. COMMISSIONER

Docket No. 25477-82.

85 T.C. 855 (1985)

COLONIAL SAVINGS ASSOCIATION AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 26, 1985.

Attorney(s) appearing for the Case

Robert A. Schnur, for the petitioners.

Mark D. Petersen, for the respondent.

GERBER, Judge:

Respondent determined a deficiency of $5,000 in petitioners' taxable year ended June 30, 1980. Due to an agreement of the parties,1 the sole issue for our consideration is whether income received by financial institutions as penalties for premature withdrawal is to be treated as income from discharge of indebtedness within the meaning of section 108.2 This is an issue of first impression...

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