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UNIONBANCAL CORP. v. COMMISSIONER

Docket No. 11364-97.

113 T.C. 309 (1999)

UNIONBANCAL CORPORATION, F.K.A. UNION BANK, SUCCESSOR IN INTEREST TO STANDARD CHARTERED HOLDINGS, INC. AND INCLUDABLE SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 22, 1999.

Attorney(s) appearing for the Case

Frederick R. Chilton, Jr., and Paolo M. Dau, for petitioner.

Cynthia K. Hustad, for respondent.

THORNTON, Judge:

Respondent determined a deficiency in petitioner's corporate Federal income tax for the taxable year ending October 31, 1988, in the amount of $1,676,690. The only issue before the Court is whether respondent erred in refusing to allow petitioner a deduction in the amount of $85,612,820 (representing losses previously deferred pursuant to section 267(f) and arising from petitioner's 1984 sale of certain...

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