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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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