BankAmerica Corporation, as successor in interest to Continental Bank Corporation, as successor in interest to Continental Illinois Corporation - Page 1

                                   109 T.C. No. 1                                     


                               UNITED STATES TAX COURT                                


          BANKAMERICA CORPORATION, as successor in interest to CONTINENTAL            
              BANK CORPORATION, as successor in interest to CONTINENTAL               
            ILLINOIS CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL              
                                 REVENUE, Respondent%                                 


               Docket No. 5931-83.              Filed July 15, 1997.                  


                    P had deficiencies in its Federal income tax for                  
               years 1 and 2.  In year 3, P carried back an amount of                 
               investment tax credit to years 1 and 2, reducing the                   


          %  This Court has issued five opinions under this docket                    
          number, each captioned Continental Illinois Corp. v.                        
          Commissioner:  T.C. Memo. 1988-318, T.C. Memo. 1989-468, T.C.               
          Memo. 1989-636, 94 T.C. 165 (1990), and T.C. Memo. 1991-66,                 
          relating to the tax liability of petitioner's predecessor for the           
          tax years 1975 through 1979.  Portions of the decisions in T.C.             
          Memo. 1988-318, T.C. Memo. 1989-636, and T.C. Memo. 1991-66 were            
          affirmed in part and reversed in part and remanded to this Court            
          in Continental Illinois Corp. v. Commissioner, 998 F.2d 513 (7th            
          Cir. 1993), cert. denied 510 U.S. 1041 (1994), and a decision was           
          entered in accordance with the opinion of the Court of Appeals              
          for the Seventh Circuit.  Petitioner has filed a timely motion to           
          redetermine interest.                                                       




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