- 17 - (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 ofPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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