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STATE OF MARYLAND DEPOSIT INS. FUND CORP. v. COMMISSIONER

Docket Nos. 26511-82, 34747-84.

88 T.C. 1050 (1987)

STATE OF MARYLAND DEPOSIT INSURANCE FUND CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 27, 1987.

Attorney(s) appearing for the Case

Harry D. Shapiro, Robert G. Nath, and Francis X. Pugh, for the petitioner.

Lawrence D. Garr, for the respondent.

SWIFT, Judge:

Petitioner State of Maryland Deposit Insurance Fund Corp. (MDIFC) is the successor corporation to Maryland Savings-Share Insurance Corp. (MSSIC). MDIFC is a nonstock, nonprofit corporation organized on May 18, 1985, by the State of Maryland to provide insurance to savings and loan associations chartered within the State. In early 1985, several savings and loan associations insured by MSSIC defaulted on their obligations. This created a crisis...

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