T.C. Memo. 1995-600
UNITED STATES TAX COURT
NORWEST CORPORATION AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13908-92. Filed December 20, 1995.
Mark Alan Hager, Robert James Jones, Thomas Richard Dwyer, and
Susan K. Matlow, for petitioner.
Robert M. Ratchford and Dana E. Hundrieser, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This matter is before the Court on
respondent's motion, and petitioner's cross-motion, for partial
summary judgment pursuant to Rule 121. Both parties submitted
memoranda in support of their positions.
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