T.C. Memo. 1997-31
UNITED STATES TAX COURT
NORWEST CORPORATION AND SUBSIDIARIES,
SUCCESSOR IN INTEREST TO DAVENPORT BANK
AND TRUST COMPANY AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25613-95. Filed January 16, 1997.
Scott G. Husaby, for petitioner.
Jack Forsberg, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: This case was assigned
pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183 for
purposes of hearing two motions filed by petitioner: (1) A
motion to dismiss for lack of jurisdiction with respect to a
1
Unless otherwise indicated, section references are to the
Internal revenue Code in effect for the year at issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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