Barnett Banks, Inc. & Subsidiaries - Page 3




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          granted with respect to all or any part of the legal issues in              
          controversy “if the pleadings, answers to interrogatories,                  
          depositions, admissions, and any other acceptable materials,                
          together with the affidavits, if any, show that there is no                 
          genuine issue as to any material fact and that a decision may be            
          rendered as a matter of law.”  Rule 121(b); Stubbs v.                       
          Commissioner, 797 F.2d 936 (11th Cir. 1986).  Respondent asserts            
          that there are material facts in dispute with respect to                    
          petitioner’s satisfaction of certain tests to qualify for the               
          reserve method in dispute and thus argues that only partial                 
          summary judgment is appropriate if we agree with petitioner’s               
          interpretation of relevant statutes and regulations.  The facts             
          material to the Court's disposition of the cross-motions for                
          summary judgment are stated solely for purposes of deciding the             
          motions and are not findings of fact for these cases.  See                  
          Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.            
          17 F.3d 965 (7th Cir. 1994).                                                
                                     Background                                       
               During the taxable years 1986 through 1994, Barnett Banks,             
          Inc. (Barnett), was an accrual basis bank holding company                   
          organized and existing under the laws of the State of Florida,              
          with its principal place of business in Jacksonville, Florida.              
          On January 9, 1998, Barnett merged into NB Holdings, a subsidiary           
          of NationsBank Corp., and thereafter was a wholly owned                     






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