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NORWEST CORPORATION v. COMMISSIONER

Docket No. 37288-86.

63 T.C.M. 3023 (1992)

T.C. Memo. 1992-282

Norwest Corporation and Affiliated Companies, Formerly Northwest Bancorporation and Affiliated Companies, Norwest Bank Fort Dodge, N.A., Formerly First National Bank, and Norwest Bank Marion, N.A., Formerly First National Bank of Marion v. Commissioner.

United States Tax Court.

Filed May 18, 1992.

Attorney(s) appearing for the Case

David R. Brennan, 90 S. Seventh St., Minneapolis, Minn., and Walter A. Pickhardt, for the petitioner. William G. Merkle, for the respondent.

Memorandum Opinion

JACOBS, Judge:

Respondent determined deficiencies in the Federal income tax of Norwest Corporation and Affiliated Companies (Norwest), Norwest Bank Fort Dodge, N.A., formerly First National Bank, and Norwest Bank Marion, H.A., formerly First National Bank of Marion. The parties have resolved their differences with respect to these deficiencies.

In the petition, Norwest claimed an overpayment of tax based on its alleged entitlement...

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