Norwest Corporation and Subsidiaries, Successor in Interest to Davenport Bank and Trust Company and Subsidiaries - Page 3

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               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.             




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