U.S. Bancorp, Successor In Interest to West One Bancorp and Subsidiaries, formerly known as Moore Financial Group, Inc. - Page 1


                                 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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