-16-
version at 12 U.S.C. secs. 21-216 (2000). By virtue of its
status as a national bank, FNBC was regulated by the Office of
the Comptroller of the Currency (OCC).
During the relevant years, FNBC was FCC’s primary
subsidiary. For Federal income tax purposes, FNBC was an accrual
method taxpayer, and it joined in the consolidated Federal income
tax returns filed by FCC.
4. Bank One Corp.
Bank One Corp. is a multibank holding company registered
under the Bank Holding Company Act of 1956, ch. 240, 70 Stat.
133, currently codified at 12 U.S.C. secs. 1841-1850 (2000). It
was incorporated in Delaware on April 9, 1998, to effect the
merger of First Chicago NBD Corp. and Banc One Corp., an Ohio
corporation and registered bank holding company. The merger was
effective October 2, 1998.3 By virtue of its status as a bank
holding company, Bank One Corp. was regulated during the relevant
years by the FRB. Bank One Corp.’s principal office was in
Chicago, Illinois, at all relevant times.
3 Shortly thereafter, the Court, pursuant to an unopposed
motion by petitioner, ordered that the caption be changed to the
present caption.
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