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U.S. BANCORP v. COMMISSIONER

Docket No. 6544-97.

76 T.C.M. 719 (1998)

T.C. Memo. 1998-381

U.S. Bancorp, Successor in Interest to West One Bancorp and Subsidiaries, Formerly known as Moore Financial Group, Inc. v. Commissioner.

United States Tax Court.

Filed October 22, 1998.

Attorney(s) appearing for the Case

David W. Brown and Richard A. Edwards, for the petitioner. William P. Boulet, Jr. and James R. Robb, for the respondent.

MEMORANDUM OPINION

BEGHE, Judge:

This matter is before the Court on petitioner's motion for partial summary judgment, as supplemented (petitioner's motion), and respondent's cross-motion for partial summary judgment under Rule 121.2 Petitioner's principal place of business was at Portland, Oregon, when it filed its petition.

Relying on Security Bank Minn. v. Commissioner [Dec. 47,941], 98 T.C. 33...

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