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(A) any bank (as defined in section
581),
(B) any institution described in
section 591,
(C) any credit union the deposits
or accounts in which are insured under
Federal or State law or are protected or
guaranteed under State law, or
(D) any similar institution
chartered and supervised under Federal or
State law.
(4) Deposit.--For purposes of this
subsection, the term "deposit" means any
deposit, withdrawable account, or withdrawable
or repurchasable share.
The parties agree that petitioner is a "qualified individual"
pursuant to section 165(l). Cf. Fincher v. Commissioner, supra.
Petitioner bears the burden to prove that the remaining statutory
requirements are met. Rule 142(a).
Preliminarily, we must determine the specific financial
institution where petitioner's funds were "on deposit". We must
then determine whether that institution was "qualified" within the
meaning of section 165(l)(3).
Petitioner argues that she had an account at BCCI, S.A. in
Luxembourg or the Los Angeles agency office of BCCI, S.A.
Respondent argues that petitioner's account was at the IOMB of
BCCI, S.A. Because the following analysis determines that none of
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