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NORWEST CORP. v. COMMISSIONER

Docket Nos. 20567-93, 26213-93.

70 T.C.M. 416 (1995)

T.C. Memo. 1995-390

Norwest Corporation and Subsidiaries v. Commissioner.

United States Tax Court.

Filed August 15, 1995.

Attorney(s) appearing for the Case

Mark Hager, Minneapolis, Minn., for the petitioner. Lawrence C. Letkewicz, for the respondent.

MEMORANDUM OPINION

JACOBS, Judge:

This matter is before the Court on respondent's motion for partial summary judgment pursuant to Rule 1211 and petitioner's cross-motion for summary judgment. Both petitioner and respondent submitted memoranda in support of their positions. At the time the petitions were filed, petitioner's principal place of business was Minneapolis, Minnesota.

Petitioner is engaged in the banking and...

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