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In Wells Fargo & Co. v. Commissioner, 224 F.3d 874 (8th Cir. 2000), rev’g in part Norwest Corporation and Subsidiaries v. Commissioner, 112 T.C. 89 (1999), the Eighth Circuit held that INDOPCO does not require capitalization of pre-acquisition investigatory and due diligence costs that are ordinary, related to the carrying on of an existing ... ................
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