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NORWEST CORP. & SUBS. v. COMMISSIONER

Docket No. 25613-95.

112 T.C. 89 (1999)

NORWEST CORPORATION AND SUBSIDIARIES, SUCCESSOR IN INTEREST TO DAVENPORT BANK AND TRUST COMPANY AND SUBSIDIARIES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 8, 1999.

Attorney(s) appearing for the Case

Mark A. Hager, John R. Kalligher, William K. Wilcox, and Walter A. Pickhardt, for petitioner.

Jack Forsberg, for respondent.

LARO, Judge:

Norwest Corp. (Norwest) & Subsidiaries, Successor in Interest to Davenport Bank & Trust Co. (DBTC) & Subsidiaries, petitioned the Court to redetermine respondent's determination of a $132,088 deficiency in DBTC's 1991 consolidated Federal income tax. Following petitioner's concessions, the only issue left to decide is whether section 162(a) allows DBTC to deduct investigatory costs, due diligence costs, and officers' salaries which...

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