111 T.C. No. 5
UNITED STATES TAX COURT
NORWEST CORPORATION AND SUBSIDIARIES, SUCCESSOR IN INTEREST TO
UNITED BANKS OF COLORADO, INC., AND SUBSIDIARIES, ET AL.,1
Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 26499-93, 3723-95, Filed August 10, 1998.
3724-95, 3725-95.
I.
P is the successor in interest to an affiliated
group of corporations whose parent corporation is
United Banks of Colorado, Inc. (the UBC affiliated
group and UBC, respectively). UBC and certain other
members of the UBC affiliated group (collectively, the
Bank) built a structure called the Atrium. P seeks to
allocate the cost of constructing the Atrium to the
bases of adjoining properties that were held by the
Bank. Alternatively, P seeks to deduct the cost of
1 The cases of the following petitioners are consolidated
herewith: Norwest Corp., Successor in Interest to United Banks
of Colorado, Inc., and Subs., docket No. 3723-95; Norwest Corp.,
Successor in Interest to Intrawest Financial Corp. and Subs.,
docket No. 3724-95; Norwest Corp., Successor in Interest to Lorin
Investment Co., Inc. and Subs., docket No. 3725-95.
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