WELLS FARGO & CO. AND SUBSIDIARIES v. C.I.R.

No. 99-3307.

224 F.3d 874 (2000)

WELLS FARGO & COMPANY AND SUBSIDIARIES, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: August 29, 2000.


Attorney(s) appearing for the Case

Walter A. Pickhardt, Minneapolis, MN, argued (Mark Alan Hager, Andrew T. Gardner, on the brief), for Appellant.

Steven W. Parks, U.S. Department of Justice, Washington, DC, argued (Gilbert S. Rothenberg, Loretta C. Argrett, Asst. Attorney General, on the brief), for Appellee.

Before LOKEN and BRIGHT, Circuit Judges, and HAND, District Judge.


HAND, District Judge.

This case is before the Court on appeal from the Tax Court, which determined that $150,000 worth of salaries paid to Davenport's corporate officers must be capitalized, rather than deducted fully during the year in which the salaries were paid. The Tax Court also held that $111,270 of fees and disbursements paid to Davenport's attorneys must capitalized. The Tax Court determined that the United States Supreme Court case, INDOPCO, Inc. v. Commissioner...

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