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term of the new lease. We hold that the charge must be
capitalized and amortized over the term of the new lease.
The background facts set forth below are derived from the
pleadings in this case, petitioner's request for admissions,
respondent's responses to petitioner's request, affidavits and
exhibits attached to petitioner's motion for partial summary
judgment, respondent’s cross-motion for partial summary judgment,
the declaration and exhibits attached to respondent's response to
petitioner's motion, the exhibits attached to petitioner's reply
to respondent's response, and the exhibits and affidavits
attached to petitioner's first and second supplemental replies to
respondent's response. The background facts do not appear to be
in dispute and are set forth solely for purposes of deciding the
motions and are not findings of fact for this case. Fed. R. Civ.
P. 52(a); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
(1992), affd. 17 F.3d 965 (7th Cir. 1994).
Background
Petitioner is a successor in interest by merger of West One
Bancorp. Moore Financial Group, Inc. (Moore Financial), was a
national bank holding company incorporated in the State of Idaho
in 1981. In 1989, Moore Financial changed its name to West One
Bancorp (West One). In 1995, West One merged into U.S. Bancorp
(Old Bancorp), a bank holding company incorporated in the State
of Oregon. In 1997, Old Bancorp merged into First Bank System,
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