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Background
All facts were stipulated or contained in the exhibits
submitted with the stipulations. The stipulated facts and
exhibits are incorporated herein by this reference. When the
petition was filed, petitioner’s mailing address and principal
place of business were in Wausau, Wisconsin.
Petitioner is a holding company and the common parent of an
affiliated group of corporations that file consolidated Federal
income tax returns. Petitioner’s common stock is held by
approximately 1,000 shareholders. The other members of the
affiliated group are petitioner’s wholly owned subsidiary
(Peoples) and Peoples’ wholly owned subsidiary (Investments).
For financial and regulatory accounting purposes, Investments and
Peoples consolidate their assets, liabilities, income, and
expenses.
Peoples was organized in 1962 as a State bank under
Wisconsin law. Peoples’ main office is located in Wausau,
Wisconsin, and it has several branch offices in Wisconsin
communities near Wausau. Peoples is petitioner’s sole
subsidiary. Peoples’ sole subsidiary is Investments.
On or about April 23, 1992, Peoples organized Investments in
Nevada. Investments does business exclusively in Nevada, with
offices in Las Vegas, Nevada, and offsite record storage at a
third-party facility in Las Vegas. Investments has no depository
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Last modified: March 27, 2008