BankAmerica Corporation, as successor in interest to Continental Bank Corporation, as successor in interest to Continental Illinois Corporation - Page 31

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                                                                                                                                                                 Petitioner's                                                                                                                     
                                                                                                                                                                Sec 7481(c)                                                                                                                       
                                                                                                                                                                   Interest                                 Nov., 1994                                                                            
                                                                                                                                                                Computation                                 Stipulation                                   Difference                              
         Determination of Deficiency to be Paid for Restricted Interest                                                                                                                                                                                                                           
         Tax liability without credit carrybacks                                                                                                                                 6,608,807                                  6,608,807                                                0            
         Tax assessed and paid                                                                                                                                                   3,633,741                                  3,633,741                                                0            
         Deficiency without allowance for carrybacks                                                                                                                             2,975,066                                  2,975,066                                                0            

         Tax liability after consideration of carryback from 1979 to 1978:                                                                                                                                                                                                                        
         Investment tax credit carryback                                                                                                                                           444,727                                           0                                        444,727             
         Total credit carryback from 1979 to 1978                                                                                                                                  444,727                                           0                                        444,727             
         Tax liability after consideration of carryback from 1979 to 1978                                                                                                        6,164,080                                  6,608,807                                        (444,727)            
         Tax assessed and paid                                                                                                                                                   3,633,741                                  3,633,741                                                0            
         Deficiency after consideration of credit carryback from 1979 to 1978                                                                                                    2,530,339                                  2,975,066                                        (444,727)            

         Tax liability after consideration of carryback from 1982 to 1978:                                                                                                                                                                                                                        
         Current year investment tax credit (freed up)                                                                                                                           (541,122)                                  (541,122)                                                0            
         Foreign tax credit carryback                                                                                                                                            1,971,695                                  1,971,695                                                0            
         Investment tax credit carryback/(freed up)                                                                                                                              (444,727)                                           0                                       (444,727)            
         Total credit carryback from 1982 to 1978                                                                                                                                1,526,968                                  1,971,695                                        (444,727)            
         Tax liability after consideration of carryback from 1982 to 1978                                                                                                        5,178,234                                  5,178,234                                                0            
         Tax assessed and paid                                                                                                                                                   3,633,741                                  3,633,741                                                0            
         Tax assessed 9/30/92 subsequent to Tax Court Decision                                                                                                                   2,076,812                                  2,076,812                                                0            
         Total assessment                                                                                                                                                        5,710,553                                  5,710,553                                                0            
         Overassessment after consideration of credit carryback from 1982 to 1978                                                                                                (532,319)                                  (532,319)                                                0            
         Tax assessed 9/30/92 subsequent to Tax Court Decision but not paid                                                                                                      2,076,812                                  2,076,812                                                0            
         Tax deficiency before taking into account 9/30/92 assessment, as                                                                                                                                                                                                                         
         reflected in the Tax Court Decision dated November 17, 1994                                                                                                             1,544,493                                  1,544,493                                                0            
         Payments and credits applied after the Tax Court Decision                                                                                                                  79,925                                     79,925                                                0            
         Deficiency after consideration of carryback from 1979 and 1982, and                                                                                                                                                                                                                      
         payments subsequent to the November 17, 1994 Tax Court Decision                                                                                                         1,464,568                                  1,464,568                                                0            

         Determination of Deficiency                                                                                                                                                                                                                                                              
         Tax liability                                                                                                                                                                                                                                                                            
         Tax liability without credit carrybacks                                                                                                                                 6,608,807                                  6,608,807                                                0            
         Current year investment tax credit (freed up)                                                                                                                           (541,122)                                  (541,122)                                                0            
         Foreign tax credit carryback                                                                                                                                            1,971,695                                  1,971,695                                                0            
         Investment tax credit carryback/(freed up)                                                                                                                                       0                                          0                                               0            
         Total credit carryback                                                                                                                                                  1,971,695                                  1,971,695                                                0            
         Tax liability after consideration of credit carryback from 1979 and 1982                                                                                                5,178,234                                  5,178,234                                                0            
         Tax assessed and paid                                                                                                                                                                                                                                                                    
         Tax assessed and paid without consideration of events subsequent                                                                                                                                                                                                                         
         to Tax Court Decision                                                                                                                                                   3,633,741                                  3,633,741                                                0            
         Tax deficiency before taking into account 9/30/92 assessment, as                                                                                                                                                                                                                         
         reflected in the Tax Court Decision dated November 17, 1994                                                                                                             1,544,493                                  1,544,493                                                0            
         Payments and credits applied after the Tax Court Decision                                                                                                                  79,925                                     79,925                                                0            
         Deficiency after consideration of carryback from 1979 and 1982, and                                                                                                                                                                                                                      
         payments subsequent to the November 17, 1994 Tax Court Decision                                                                                                         1,464,568                                  1,464,568                                                0            

















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