Norwest Corporation and Subsidiaries - Page 6

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               The issues for decisions are:1 (1) Whether petitioner is               
          entitled to deduct the costs of removing asbestos-containing                
          materials from its Douglas Street bank building; (2) whether                
          petitioner realized a loss on a Brazilian debt-equity conversion;           
          and (3) whether any portion of the $141,456,620 petitioner paid to          
          acquire the assets of Financial Investment Associates, Inc., should         
          be  allocated  to  goodwill,  going-concern  value,  or  other              
          nonamortizable intangible assets.                                           
               All section references are to the Internal Revenue Code in             
          effect for the years under consideration.  All Rule references are          
          to the Tax Court Rules of Practice and Procedure.                           
               For convenience and clarity, we have combined our findings of          
          fact and opinion with respect to each issue.  Some of the facts             
          have been stipulated and are found accordingly.  The stipulations           
          of facts and the attached exhibits are incorporated herein by this          
          reference.                                                                  
                                  General Findings                                    
               Norwest Corporation (hereinafter petitioner or Norwest), a             
          Delaware corporation, had its principal place of business in                
          Minneapolis, Minnesota, at the time the petitions were filed.               
          Norwest is the parent company of a group of corporations that filed         

               1    With the exception of certain issues relating to                  
          foreign tax credits and petitioner's claim for additional                   
          research credits, all other issues have been resolved.                      
                    The increased deficiencies asserted in the answers and            
          amended answers are not attributable to any issues before this              
          Court.                                                                      




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