Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 5

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          After concessions by the parties, the issues remaining for                  
          decision are (1) whether petitioner may allocate the cost of                
          certain property to the bases of other properties, (2) whether              
          petitioner is entitled to a loss deduction under section 165(a)             
          for the cost of certain property, (3) whether petitioner may                
          disavow the form of a transaction relating to certain property,             
          (4) whether petitioner is entitled to refunds of tax paid                   
          pursuant to section 56(a), (5) the applicable recovery period for           
          determining depreciation deductions with respect to certain                 
          furniture and fixtures, and (6) the appropriate method for                  
          determining that portion of a consolidated net operating loss               
          attributable to the bad debt deductions of the bank members of an           
          affiliated group.  Some of the facts have been stipulated and are           
          so found.  The stipulations of facts filed by the parties, with             
          accompanying exhibits, are incorporated herein by this reference.           
          The parties have made 150 separate stipulations of fact,                    
          occupying more than 40 pages, and there are 174 accompanying                
          exhibits.  We shall set forth only those stipulated facts that              
          are necessary to understand our report, along with other facts              
          that we find.                                                               
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  






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