BankAmerica Corporation, as successor in interest to Continental Bank Corporation, as successor in interest to Continental Illinois Corporation - Page 29

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                    ITC.  In the end, after taking into account the effects of the                                                                                        
                    1982 NOL, petitioner's ultimate tax liability was reduced by the                                                                                      
                    1979 ITC only once, namely, in 1981.  In addition, the 1979 ITC                                                                                       
                    reduced petitioner's liability for interest on any deficiency                                                                                         
                    from the point at which it was paid, first for the 1977 and 1978                                                                                      
                    tax years from January 1, 1980, to March 14, 1983, and then for                                                                                       
                    the 1981 tax year from March 15, 1983, onward.  There is no                                                                                           
                    overlap of periods to which the 1979 ITC was applied for purposes                                                                                     
                    of interest or liability for deficiencies.                                                                                                            
                              To reflect the foregoing,                                                                                                                   
                                                                                          An appropriate order will                                                       
                                                                                be issued.                                                                                

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