Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 3

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               Equipment) of Rev. Proc. 87-56, 1987-2 C.B. 674, should                
               be classified as class 57.0 property.  Held:  Rev.                     
               Proc. 87-56 carries forward the pattern established in                 
               Rev. Proc. 62-21, 1962-2 C.B. 418; the priority rule of                
               Rev. Proc. 62-21 is implicit in Rev. Proc. 87-56:                      
               Asset guideline class 00.11 takes precedence over asset                
               guideline class 57.0.                                                  
                                         V.                                           
                    P claims that, in determining the portion of the                  
               UBC affiliated group’s consolidated net operating loss                 
               (NOL) that is attributable to bad debt deductions of                   
               bank members, and is, thus, subject to the special                     
               10-year carryback rule of sec. 172(b)(1)(L), I.R.C., it                
               can apply the special loss ordering rule of sec.                       
               172(l)(1), I.R.C., to the consolidated NOL of both bank                
               and nonbank members.  Held:  The consolidated return                   
               regulations contemplate that the consolidated NOL is                   
               comprised of the separate taxable income, including                    
               separate NOL, of each member, and the special ordering                 
               rules of sec. 172(l)(1), I.R.C., apply to a bank not                   
               between a bank member and a nonbank member of an                       
               affiliated group.                                                      


               Walter A. Pickhardt, Mark Hager, and Scott G. Husaby for               
          petitioners.                                                                
               Jack Forsberg, Tracy Martinez, Robert M. Ratchford, and                
          David L. Zoss, for respondent.                                              
                                       OPINION                                        

               HALPERN, Judge:  Norwest Corp. (Norwest), a Delaware                   
          corporation, is the petitioner in each of these consolidated                
          cases.  Norwest is the petitioner by virtue of being the                    
          successor in interest to various other corporations.  When                  
          necessary for clarity, we shall refer by name to Norwest or one             
          or the other of those predecessor corporations.  Otherwise, we              




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