Norwest Corporation and Subsidiaries - Page 7

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          consolidated corporate income tax returns for the years under               
          consideration (1987 through 1989). Petitioner reports its income on         
          a calendar-year basis, employing the accrual method of accounting.          
          Petitioner timely filed its U.S. Corporation Income Tax Returns for         
          1987, 1988, and 1989.                                                       
          Issue I.  Removal of Asbestos-Containing Materials                          
               The first issue is whether petitioner is entitled to deduct            
          the costs of removing asbestos-containing materials from its                
          Douglas Street bank building.  Petitioner argues that the                   
          expenditures constitute section 162(a) ordinary and necessary               
          expenses. Respondent, on the other hand, contends that the                  
          expenditures must be capitalized pursuant to section 263(a)(1).             
          Alternatively, respondent contends that the expenditures must be            
          capitalized pursuant to the "general plan of rehabilitation"                
          doctrine.                                                                   
               A. The Douglas Street Building                                         
               One of petitioner's subsidiaries, Norwest Bank Nebraska, N.A.          
          (Norwest Nebraska), owns a building at 1919 Douglas Street in               
          Omaha, Nebraska (the Douglas Street building or building). The              
          Douglas Street building is a three-story commercial office building         
          that occupies half a square block and has a lower level parking             
          garage. Norwest Nebraska constructed the building in 1969 at a              
          $4,883,232 cost.  During all relevant periods, Norwest Nebraska             
          used the Douglas Street building as an operations center as well as         
          a branch for serving customers.                                             




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