Norwest Corporation and Subsidiaries, Successor in Interest to Davenport Bank and Trust Company and Subsidiaries - Page 1

                                 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                

               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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