Norwest Corp. v. Comm'r
United States Tax Court
I. P is the successor in interest to an affiliated group of corporations whose parent corporation is United Banks of Colorado, Inc. (the UBC affiliated group and UBC, respectively). UBC and certain other members of the UBC affiliated group (collectively, the Bank) built a structure called the Atrium. P seeks to allocate the cost of constructing the Atrium to the bases of adjoining properties that were held by the Bank.
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I. P is the successor in interest to an affiliated group of corporations whose parent corporation is United Banks of Colorado, Inc. (the UBC affiliated group and UBC, respectively). UBC and certain other members of the UBC affiliated group (collectively, the Bank) built a structure called the Atrium. P seeks to allocate the cost of constructing the Atrium to the bases of adjoining properties that were held by the Bank. Alternatively, P seeks to deduct the cost of constructing the Atrium under sec. 165(a), I.R.C. HELD: P may not allocate the cost of constructing the Atrium to the bases of the…
1Opinion of the Court
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 the predecessor corporations.
These consolidated cases involve determinations by respondent of deficiencies in petitioner’s Federal income taxes and…
2Cases cited48 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
- Commissioner v. DanielsonCourt of Appeals for the Third Circuit · 1967
- Danielson v. CommissionerUnited States Tax Court · 1965
43 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
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- Intermet Corporation & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Framatome Connectors USA, Inc. v. Comm'rUnited States Tax Court · 2002
- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013
- Intermet Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1998
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