Barnett Banks, Inc. & Subsidiaries - Page 9




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          Pinellas County (Pinellas).  Thereafter, Pinellas became a                  
          subsidiary of Barnett and a member of its consolidated group for            
          Federal income tax purposes.                                                
               Pinellas’s board of directors consisted of the current                 
          directors of Barnett Bank of Pinellas County, N.A., and Home                
          Federal.  In addition, Alfred T. May, the president and chief               
          executive officer of Home Federal, served as the president and              
          chief operating officer of Pinellas.  Pinellas also continued to            
          use all employees in the combined organization.                             
               Pinellas’s deposits were insured by the FDIC and, after                
          FIRREA, by the BIF.                                                         
          Bad Debt Reserve Method of Accounting                                       
               After their acquisitions by Barnett, Southwest and Pinellas            
          were members of Barnett's consolidated group for Federal income             
          tax purposes.  Barnett timely filed (pursuant to extensions) a              
          Form 1120, U.S. Corporation Income Tax Return, for each of its              
          taxable years 1986 through 1994.  For all relevant years,                   
          petitioner used a fiscal year ended December 31.                            
               For each of the taxable years in issue, Barnett took the               
          position that Southwest and Pinellas qualified as "domestic                 
          building and loan associations" within the meaning of section               
          7701(a)(19); as a result, Barnett claimed a deduction for                   
          Southwest’s and Pinellas’s bad debts based on the reserve method            
          of accounting under former section 593.  Barnett attached the               






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