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RIGGS NATIONAL CORPORATION & SUBSIDIARIES v. COMMISSIONER

Docket No. 24368-89.

87 T.C.M. 1276 (2004)

T.C. Memo. 2004-110

Riggs National Corporation & Subsidiaries, f.k.a. Riggs National Bank and Subsidiaries v. Commissioner.

United States Tax Court.

Filed May 3, 2004.

Attorney(s) appearing for the Case

Joel V. Williamson, Thomas C. Durham, Gary S. Colton, Jr., Russell R. Young, Charles W. Hall, and Stephen M. Feldhaus, for petitioner.

Theodore J. Kletnick and Courtney L. Shepardson, for respondent.

SUPPLEMENTAL MEMORANDUM FINDINGS OF FACT AND OPINION

JACOBS, Judge:

This case is before the Court on remand from the U.S. Court of Appeals for the District of Columbia Circuit for further consideration consistent with its opinion in Riggs Natl. Corp. & Subs. v. Commissioner [2002-2 USTC ¶ 50,521], 295 F.3d 16 (D.C. Cir. 2002) (Riggs IV), revg. and remanding [Dec. 54,216(M)] T.C. Memo. 2001...

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