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NORWEST CORP. & SUBS. v. COMMISSIONER

Docket Nos. 26499-93, 3723-95, 3724-95, 3725-95.

111 T.C. 105 (1998)

NORWEST CORPORATION & SUBSIDIARIES, SUCCESSOR IN INTEREST TO UNITED BANKS OF COLORADO, INC., & SUBSIDIARIES, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 10, 1998.

Attorney(s) appearing for the Case

Walter A. Pickhardt, Mark Hager, and Scott G. Husaby, for petitioners.

Jack Forsberg, Tracy Martinez, Robert M. Ratchford, and David L. Zoss, for respondent.

OPINION

HALPERN, Judge:

Norwest Corp. (Norwest), a Delaware corporation, is the petitioner in each of these consolidated cases. Norwest is the petitioner by virtue of being the successor in interest to various other corporations. When necessary for clarity, we shall refer by name to Norwest or one or the other of those predecessor corporations. Otherwise, we shall use the term "petitioner" to refer without distinction to Norwest or one or more of...

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