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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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