- 2 - acts and omissions occurring before the transaction. The due diligence costs relate to services performed by L in connection with N's due diligence review. The disallowed officers' salaries were attributable to the transaction. Held: Sec. 162(a), I.R.C., does not let D deduct any of the disputed costs. Mark A. Hager, John R. Kalligher, William K. Wilcox, and Walter A. Pickhardt, for petitioner. Jack Forsberg, for respondent. LARO, Judge: Norwest Corp. (Norwest) and Subsidiaries, Successor in Interest to Davenport Bank and Trust Co. (DBTC) and Subsidiaries, petitioned the Court to redetermine respondent's determination of a $132,088 deficiency in DBTC's 1991 consolidated Federal income tax. Following petitioner's concessions, the only issue left to decide is whether section 162(a) allows DBTC to deduct investigatory costs, due diligence costs, and officers' salaries which respondent determined were attributable to an acquisition of DBTC. We hold that DBTC may not deduct any of these costs. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the subject year. Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts are rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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