Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 8

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               On April 19, 1991, United Banks of Colorado, Inc. (UBC), a             
          Colorado corporation, was merged with and into Norwest pursuant             
          to section 368(a)(1)(A).  At all relevant times prior to its                
          merger with Norwest, UBC was the common parent corporation of an            
          affiliated group of corporations making a consolidated return of            
          income (the UBC affiliated group).  UBC was a calendar-year                 
          taxpayer.  Petitioner is the successor in interest to the UBC               
          affiliated group as it existed during the years in issue.                   
               On May 1, 1987, Intrawest Financial Corp. (Intrawest), a               
          Colorado corporation, was merged with and into UBC pursuant to              
          section 368(a)(1)(A).  At all relevant times prior to its merger            
          with UBC, Intrawest was the common parent corporation of an                 
          affiliated group of corporations making a consolidated return of            
          income (the Intrawest affiliated group).  Petitioner is the                 
          successor in interest to the Intrawest affiliated group for its             
          taxable year 1980 and its short taxable year ended April 30,                
          1987.                                                                       
               On April 1, 1982, UBC purchased for cash the stock of Lorin            
          Investment Co., Inc. (Lorin), a Colorado corporation.  At all               
          relevant times prior to being acquired by UBC, Lorin was the                
          common parent corporation of an affiliated group of corporations            
          making a consolidated return of income (the Lorin affiliated                
          group).  Petitioner is the successor in interest to the Lorin               
          consolidated group for its taxable years 1980 and 1981.                     






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