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CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES v. COMMISSIONER OF INTERNAL REVENUE

Nos. 19519-05, 24260-05

133 T.C. No. 8

CAPITAL ONE FINANCIAL CORPORATION AND SUBSIDIARIES, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 21, 2009.

Attorney(s) appearing for the Case

Jean Ann Pawlow, Elizabeth A. Erickson, Holly K. Hemphill, Kevin Spencer, and Robin L. Greenhouse, for petitioners.

Gary D. Kallevang, James D. Hill, and Alan R. Peregoy, for respondent.

HAINES, Judge:

Respondent determined deficiencies in, and penalties with respect to, petitioners' Federal income taxes as follows:1

Penalty Year Deficiency Sec. 6662(a) 1995 $1,459,146 N/A 1996 ...

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