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NORWEST CORP. v. C.I.R.

Nos. 93-1274, 93-1741.

69 F.3d 1404 (1995)

NORWEST CORPORATION, formerly known as Northwest Bancorporation and Affiliated Companies, and Affiliated Companies, Appellant/Cross-appellee, Norwest Bank, Fort Dodge, N.A., formerly First National Bank, and; Norwest Bank, Marion, N.A., formerly First National Bank of Marion, v. COMMISSIONER OF INTERNAL REVENUE, Appellee/Cross-appellant.

United States Court of Appeals, Eighth Circuit.

Decided November 14, 1995.

Attorney(s) appearing for the Case

Thomas C. Durham, Chicago, Illinois, argued (Joel V. Williamson, Arthur I. Gould, and Roger J. Jones, on the brief), for appellant.

Charles Bricken, U.S. Dept. of Justice, Washington, DC, argued (David English Carmack, on the brief), for appellee.

Before McMILLIAN and MAGILL, Circuit Judges, and JACKSON, District Judge.

McMILLIAN, Circuit Judge.

Norwest Corporation and Affiliated Companies (Norwest) appeal from a final order entered in the United States Tax Court1 assessing and ordering Norwest to pay income tax deficiencies for its 1980 and 1982 taxable years. Norwest Corp. v. Commissioner, 63 T.C.M. (CCH) 3023, 1992 WL 103666 (1992). For reversal, Norwest claims that the tax court improperly held that it was...

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