Norwest Corp. v. Comm'r
United States Tax Court
I. Norwest Bank Nebraska, N.A., a subsidiary of petitioner, removed asbestos-containing materials from its Douglas Street building in connection with the building's renovation and remodeling. On its 1989 return, petitioner claimed a $ 902,206 ordinary and necessary business deduction with respect to the asbestos-removal expenditures. In the notice of deficiency, respondent disallowed the deduction.
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I. Norwest Bank Nebraska, N.A., a subsidiary of petitioner, removed asbestos-containing materials from its Douglas Street building in connection with the building's renovation and remodeling. On its 1989 return, petitioner claimed a $ 902,206 ordinary and necessary business deduction with respect to the asbestos-removal expenditures. In the notice of deficiency, respondent disallowed the deduction. Held: The costs of removing the asbestos-containing materials must be capitalized because they were part of a general plan of rehabilitation and renovation that improved the Douglas Street…
1Opinion of the Court
CONTENTS
Page
269 General Findings .
270 Issue I. Removal of Asbestos-Containing Materials
270 A. The Douglas Street Building.
270 B. Remodeling Plans .
C. Use of Asbestos-Containing Materials in the Douglas Street Building . 271
D. Federal Asbestos Guidelines . tH <N
273 E. Testing at the Douglas Street Building and Decision To Remove Asbestos-Containing Materials.
F. Contractors and Work Performed . 274
G. Health Concerns. 276
H. Liability Issues. 276
I. Tax and Accounting Matters . 277
J. Petitioner’s Returns and Petitions . 278
K. Notice of Deficiency. 278
Discussion . 278
L. Capital Expenditures vs.…
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