Norwest Corp. v. Commissioner
United States Tax Court
D and N entered into a transaction that resulted in N's owning all the stock of an entity of which D was a part. P concedes that sec. 263(a), I.R.C., requires that D capitalize the costs that were directly related to the transaction. P disputes R's determination that sec. 162(a), I.R.C., does not let D deduct investigatory and due diligence costs and all of its officers' salaries.
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D and N entered into a transaction that resulted in N's owning all the stock of an entity of which D was a part. P concedes that sec. 263(a), I.R.C., requires that D capitalize the costs that were directly related to the transaction. P disputes R's determination that sec. 162(a), I.R.C., does not let D deduct investigatory and due diligence costs and all of its officers' salaries. The investigatory costs relate primarily to services rendered by L, a law firm, before D agreed to participate in the transaction. D retained L to investigate whether a reorganization-like transaction with N would…
1Opinion of the Court
NORWEST CORPORATION AND SUBSIDIARIES, SUCCESSOR IN INTEREST TO DAVENPORT BANK AND TRUST COMPANY AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Norwest Corp. v. Commissioner
No. 25613-95
United States Tax Court
112 T.C. 89; 1999 U.S. Tax Ct. LEXIS 9; 112 T.C. No. 9;
March 8, 1999, Filed
Decision will be entered under Rule 155.
D and N entered into a transaction that resulted in N's
owning all the stock of an entity of which D was a part. P
concedes that sec. 263(a), I.R.C., requires that D capitalize
the costs that were directly related to the transaction. P
disputes R's…
2Cases cited31 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Newark Morning Ledger Co. v. United StatesSupreme Court of the United States · 1993
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
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