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whether petitioner is entitled to a deduction for its California
franchise tax liability in the amount of $932,979 on its Federal
income tax return for the 9-month period ending December 31,
1988.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and supplemental stipulation of facts
are incorporated herein by this reference. At the time its
petition was filed, petitioner’s principal place of business was
located in San Francisco, California.
Petitioner is a consolidated group consisting of The Charles
Schwab Corp.; its first-tier subsidiary, Schwab Holdings, Inc.;
and its second-tier operating subsidiary, Charles Schwab & Co.,
Inc. Petitioner provides discount securities brokerage and
related financial services, primarily to individuals, throughout
the United States. During the years in issue, petitioner was a
member of all major U.S. securities exchanges and had software
links with all registered U.S. securities exchanges, major
dealers, the National Securities Clearing Corp., and the
Depository Trust Co. During the relevant years, petitioner filed
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