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BANKAMERICA CORP. v. COMMISSIONER

Docket No. 5931-83.

109 T.C. 1 (1997)

BANKAMERICA CORPORATION, AS SUCCESSOR IN INTEREST TO CONTINENTAL BANK CORPORATION, AS SUCCESSOR IN INTEREST TO CONTINENTAL ILLINOIS CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 15, 1997.

Attorney(s) appearing for the Case

Roger J. Jones and Jeffrey B. Frishman, for petitioner.

Pamela V. Gibson and Richard G. Goldman, for respondent.

SUPPLEMENTAL OPINION

TANNENWALD, Judge:

A decision was entered in this case on November 17, 1994, pursuant to a stipulated computation, in accordance with the opinion of the Court of Appeals for the Seventh Circuit in Continental Ill. Corp. v. Commissioner, 998 F.2d 513 (7th Cir. 1993), cert. denied 510 U.S. 1041 (1994). On December 20, 1995, petitioner filed a timely motion under section 7481(c)

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