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
NORWEST CORPORATION AND SUBSIDIARIES, SUCCESSOR IN INTEREST TO UNITED BANKS OF COLORADO, INC., AND SUBSIDIARIES, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. NORWEST CORPORATION AND SUBSIDIARIES, SUCCESSOR IN INTEREST TO UNITED BANKS OF COLORADO, INC., AND SUBSIDIARIES, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Norwest Corp. v. Comm'r
Tax Ct. Dkt. No. 26499-93. Docket Nos. 3723-95, 3724-95, 3725-95
United States Tax Court
111 T.C. 105; 1998 U.S. Tax Ct. LEXIS 41; 111 T.C. No. 5;
August 10, 1998, Filed
I
P is the successor in interest to an…
2Cases cited51 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
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