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PACIFIC FIRST FED. SAV. BANK v. COMMISSIONER

Docket No. 27606-87.

101 T.C. 117 (1993)

PACIFIC FIRST FEDERAL SAVINGS BANK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 28, 1993.

Attorney(s) appearing for the Case

Alan S. Kaden and John F. Coverdale, for petitioner.

Fera Wagner and Richard Osborne, for respondent.

SUPPLEMENTAL OPINION

WELLS, Judge:

The instant case is before us on remand from the Court of Appeals for the Ninth Circuit. In Pacific First Fed. Sav. Bank v. Commissioner, 961 F.2d 800 (9th Cir. 1992), revg. and remanding 94 T.C. 101 (1990), the Court of Appeals reversed our decision that section 1.593-6A(b)(5)(vi) and (vii), Income Tax Regs., adopted in 1978 (the 1978 regulations...

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