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Table 1 shows the investment portfolios of the Sley
Corporations for 1980 through 1986. The values shown are the
historical costs of these assets. Apart from the limited buying
and selling of certificates of deposit and moving money from one
bank or account to another done by petitioner, see infra, the
1984 Girard Holding Co., Inc., land and parking lot sale, and the
1985 Twelfth and Sansom Corp. liquidation, the assets held by the
Sley Corporations did not change during the years in issue. The
cash management accounts shown in table 1 were accounts held at
the trust department of a bank; the trust department
automatically fully invested the accounts’ income and principal
on a daily basis.
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