U.S. Bancorp & Subsidiaries v. Department of Revenue

HENRY C. BREITHAUPT, Judge.

I. INTRODUCTION

This court has previously considered matters involving notices of assessment and/or deficiency issued by Defendant Department of Revenue (the department) to U.S. Bancorp (taxpayer) for the 1984 through 1992 tax years. See US Bancorp v. Dept. of Rev., 13 OTR 84 (1994) (Bancorp 7) (reversing assessments of additional tax upon finding that taxpayer’s merger was consistent with its regular business activities, that the sale of preferred stock was apportionable business income, and that taxpayer was permitted to file a combined return for 1987); U.S.…