PER CURIAM:
Sovran Bank/D.C. National (Sovran) appeals from an order of the trial court denying Sovran a refund for franchise taxes paid by Sovran for the years 1989 and 1990. Sovran claims that it was entitled to a deduction for certain net operating losses (NOLs) pursuant to D.C.Code § 47-1803.3(a)(14) (1997) (the NOL statute), which provides as follows:
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