- 3 - Petitioner is a corporation and is the parent company of a group of corporations that files consolidated corporate income tax returns. At the time the petition was filed, petitioner's principal place of business was Minneapolis, Minnesota. The issue presented by petitioner's motions arises over the legal and accounting fees described above that were incurred during 1991 in connection with the acquisition of the Davenport Bank and Trust Co. and its merger into Bettendorf Bank, the latter of which is a subsidiary of Norwest Corp.3 The merger of these two banks was completed on January 19, 1992. In petitioner's consolidated income tax return for 1991, petitioner claimed, as an ordinary and necessary business deduction, expenses incurred during 1991 regarding the expansion of its financial services business (banking) within the geographic area known as the "Quad Cities" of Davenport and Bettendorf, Iowa, and Moline and Rock Island, Illinois, which expansion resulted in the acquisition of the Bettendorf Bank and the merger of that bank into petitioner's consolidated group. Petitioner included with its Federal income tax return for 1991 a 3 Hereafter, references to petitioner include Norwest Corp. and all its subsidiaries that are part of its consolidated group that includes Davenport Bank and Trust Co. and Bettendorf Bank.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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