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C. Relevant Taxpayers
1. FCC
FCC was a Delaware corporation and registered bank holding
company. By virtue of its status as a bank holding company, FCC
was regulated during the relevant years by the U.S. Federal
Reserve Board (FRB). At all relevant times, including at the
time of the filing of its petition to this Court, FCC’s principal
place of business was in Chicago, Illinois.
For Federal income tax purposes, FCC was an accrual method
taxpayer that joined with its affiliates in the filing of
consolidated Federal income tax returns. FCC filed those returns
timely and on the basis of the calendar year.
2. First Chicago NBD Corp.
First Chicago NBD Corp. was a Delaware corporation and
registered bank holding company. First Chicago NBD Corp. was the
corporation resulting from the merger, effective December 1,
1995, of FCC with and into NBD Bancorp, Inc., a Delaware
corporation and registered bank holding company. At all relevant
times, including at the time of the filing of its petition to
this Court, the principal place of business of First Chicago NBD
Corp. was in Chicago, Illinois.
3. FNBC
FNBC was a national bank organized and existing as a
national banking association under the National Bank Act, current
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