Norwest Corporation and Subsidiaries - Page 2

                  Our task in connection with these motions is to determine the                       
           proper methodology to be used in calculating the amount of                                 
           petitioner's "regular tax deduction" for purposes of computing its                         
           minimum tax liability under section 56 for the years at issue.                             
                  All Rule references are to the Tax Court Rules of Practice and                      
           Procedure.  All section references are to the Internal Revenue Code                        
           in effect for the years at issue.                                                          
                  Petitioner is a group of affiliated corporations, the common                        
           parent of which is Norwest Corporation.  At the time the petition                          
           was filed, petitioner’s principal place of  business  was                                  
           Minneapolis, Minnesota.                                                                    
                  During each of the years at issue herein (1983, 1984, and                           
           1986), the affiliated group filed consolidated Federal income tax                          
           returns.  On these consolidated returns, petitioner reported the                           
           amount of its minimum tax under section 56(a) by computing what                            
           each member's minimum tax liability would have been had it filed a                         
           separate return and then aggregated these amounts. In computing                            
           each member's minimum tax liability, petitioner calculated each                            
           member's tax preference items, as well as each member's regular tax                        
           deduction, on a separate return basis.                                                     
                  Respondent determined that petitioner improperly calculated                         
           its regular tax deduction which, according to respondent, resulted                         
           in petitioner’s overstating its regular tax deduction  and                                 
           understating its consolidated minimum tax liability.  Consequently,                        

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