Norwest Corporation and Subsidiaries - Page 9

                                                 -9-                                                  
            115 Cong. Rec. 38,297-38,298 (1969) (statement of Sen. Miller).                           
                  We have considered all of petitioner's other arguments and                          
            find none persuasive.                                                                     
                  In conclusion, we hold that the amount of the section 56(c)                         
            deduction is limited to the amount of regular tax imposed on the                          
            consolidated taxable income of the affiliated group.                                      
                                                An order granting respondent's                        
                                          motion for partial  summary  judgment                       
                                          and denying petitioner's cross-motion                       
                                          will be issued.                                             





























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