NOTES 413 Tax Lawyer, Vol. 54, No. 2 NOTE WHEN ARE PRE-MERGER OFFICER SALARIES AND INVESTIGATORY EXPENSES DEDUCTIBLE UNDER SECTION 162? THE EIGHTH CIRCUIT’S ANSWER IN: WELLS FARGO & CO. V. COMMISSIONER In Wells Fargo & Co. v. Commissioner,1 the U.S. Court of Appeals for the Eighth Circuit held that salaries paid to corporate officers who provided services in connection with a capital acquisition were deductible as ordinary business expenses under section 162 of the Code. The Eighth Circuit also...