Norwest Corporation and Subsidiaries - Page 6

            (computed on a separate return basis) bore to the sum of the                              
            separate return regular taxes of all the members.  An additional                          
            amount of tax was then allocated to each member that had positive                         
            taxable income.  The additional amount allocated was the excess of                        
            the member's separate return tax over the tax already allocated to                        
            the member.                                                                               
                  As support for its computation of its corporate minimum tax,                        
            petitioner posits that, in the absence of specific statutory or                           
            regulatory guidance, it was reasonable for petitioner to calculate                        
            the section 56(c) deduction for "taxes imposed" by using the                              
            methodology set forth in the consolidated return regulations.                             
            Petitioner contends that its calulation of the section 56(c)                              
            regular tax deduction "simply followed the dictates" of that part                         
            of section 1.1552-1(b)(2), Income Tax Regs., which provides:                              
                  The amount of tax liability allocated to a corporation as                           
                  its share of the tax liability of the group * * * [under                            
                  the 1502-33(d) Method] shall (i) result in a decrease in                            
                  the earnings and profits of such corporation in such                                
                  amount, and (ii) be treated as a liability of such                                  
                  corporation for such amount. * * * (Emphasis added.)                                
                  As previously noted, section 1.1502-33(d), Income Tax Regs.,                        
            relates to the allocation of the group’s tax in determining a                             
            member’s earnings and profits.  We fail to see any meaningful                             
            relationship between the allocation required in section 1552 and                          
            the determination of the regular tax deduction for purposes of                            
            section 56.                                                                               
                  Further, petitioner quotes only a portion of section 1.1552-                        

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