T.C. Memo. 1998-381
UNITED STATES TAX COURT
U.S. BANCORP, SUCCESSOR IN INTEREST TO WEST ONE
BANCORP AND SUBSIDIARIES, FORMERLY KNOWN AS MOORE
FINANCIAL GROUP, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6544-97.1 Filed October 22, 1998.
David W. Brown and Richard A. Edwards, for petitioner.
William P. Boulet, Jr. and James R. Robb, for respondent.
1 On Nov. 18, 1997, the Court granted petitioner's motion to
consolidate this case with the case at docket No. 27342-96.
Because the issue herein is not related to the issues in docket
No. 27342-96 and does not involve the tax years at issue in
docket No. 27342-96, the order pursuant to this opinion will be
issued only in docket No. 6544-97. Also for this reason, the
Court, by order dated Sept. 15, 1998, has denied petitioner’s
motion for partial summary judgment, as supplemented, and
respondent’s cross-motion for partial summary judgment on the
interest on short-term receivables issue in the case at docket
No. 27342-96.
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