Cases

United States Court of Appeals For the Eighth Circuit ___________________________ No. 17-3578 ___________________________ Wells Fargo & Company, on behalf of itself and the members of its affiliated group filing a consolidated return lllllllllllllllllllllPlaintiff - Appellant

STOLL, Circuit Judge. The United States appeals from the Court of Federal Claims’ order granting Wells Fargo & Company’s motion for partial summary judgment and denying the government’s motion for partial summary judgment. The court held that Wells Fargo’s interest-netting claims under § 6621(d) of the Internal Revenue Code (“I.R.C.”)

Tax; Interest Netting under 26 U.S.C. § 6621(d); “Same Taxpayer”; Merged Corporations AMENDED OPINION FIRESTONE, Judge. This case presents an issue of first impression regarding the application of Internal Revenue Code (“I.R.C,” or “Code”) § 6621(d) to corporations that have acquired other corporations or been acquired through a stat

OPINION FIRESTONE, Judge. This case presents an issue of first impression regarding the application of Internal Revenue Code (“I.R.C.” or “Code”) § 6621(d) to corporations that have acquired other corporations or been acquired through a statutory merger. It concerns whether plaintiff, Wells Fargo & Company (“Wells Fargo”), is entitled to net the interes

ORDER Patrick J. Schütz, United States District Judge • This long-running tax litigation arises out of an extraordinarily complex transaction that plaintiff Wells Fargo & Company (“Wells Fargo”) engaged in with Barclays, a British financial-services company. The transaction — called “Structured Trust Advantaged Repackaged Securities” or “STARS” — included four key elements: (1) Wells Fargo wo

ORDER Patrick J. Schütz, United States District Judge In 2001, Barclays Bank, PLC — a British financial-services company — started marketing to American banks a product called “Structured Trust Advantaged Repackaged Securities” or “STARS.” Barclays proposed to American banks that they partner with Barclays in a series of complicated transactions designed to exploit differences between the tax laws of the

ORDER PATRICK J. SCHILTZ, District Judge. This matter is before the Court on the objection of plaintiff Wells Fargo & Company (‘Wells Fargo”) to the special master’s March 20, 2012 order and report [Docket No. 222]. In the order and report, the special master denied Wells Fargo’s motion for partial summary judgment on Count 4 of its amended complaint. The Court has conducted a de novo review pur

750 F.Supp.2d 1049 (2010) WELLS FARGO & COMPANY, on behalf of itself and the members of its affiliated group filing a consolidated return, Plaintiff, v. UNITED STATES of America, Defendant. Case No. 09-CV-2764 PJS AJB. United States District Court, D. Minnesota. October 27, 2010. *1050 B. John Williams, Jr., Julia M. Kazaks,

BRYSON, Circuit Judge. This case requires us to evaluate the federal income tax consequences of sale-in, lease-out (“SILO”) transactions. The Court of Federal Claims denied Wells Fargo $115 million in claimed deductions for tax year 2002 stemming from its partic *1321 ipation in 26 SILO transaction

OPINION AND ORDER WHEELER, Judge. In this tax refund suit, Plaintiff Wells Fargo & Company (“Wells Fargo”) claims $115,174,203.00 in depreciation, interest and transaction cost deductions for the tax year 2002. The deductions stem from Wells Fargo’s participation in 26 leveraged lease transactions, seventeen with domestic transit agencies, and nine involving qualified technological equipment (

GRASZ, Circuit Judge. John Meiners ("Meiners") appeals from the district court's 1 order dismissing his Complaint for failure to state a claim pursuant to Fed. R. Civ. P. 12(b)(6). Meiners claimed that his former employer, Wells Fargo & Company ("Wells Fargo"), and an assortment of Wells Fargo executives and entities (colle

United States Court of Appeals for the Federal Circuit ______________________ May 2, 2010 ERRATA ______________________ Appeal No. 2010-5108 WELLS FARGO & COMPANY AND SUBSIDIARIES, v. UNITED STATES. Decided: April 15, 2011 Precedential Opinion ______________________ Please make the following change: Page 18, line 12

United States Court of Appeals for the Federal Circuit __________________________ April 28, 2011 ERRATA ______________________ 2010-5108 WELLS FARGO & COMPANY AND SUBSIDIARIES, Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee. Appeal from the United States Court of Federal

MEMORANDUM DECISION & ORDER COGAN, District Judge. Before me is defendants’ motion to dismiss the Third Amended Complaint in its entirety for failure to state a claim. Rela-tors bring this qui tam action under the False Claims Act, 31 U.S.C. § 3729 et seq. (“FCA”), alleging essentially that defendants and their predecessors in interest presented false information to the Fe

PER CURIAM: This False Claims Act (“FCA”) case returns to us on remand from the United States Supreme Court. The Supreme Court vacated and remanded our earlier opinion, Bishop v. Wells Fargo & Co., 823 F.3d 35 (2d Cir. 2016), in light of the Supreme Court’s decision in Universal Health Services, Inc. v. United States ex rel. Escobar, — U.S. -, 136 S.Ct. 1989, 195 L.Ed.2d 348 (2016). See Bishop v. Well

On petition for writ of certiorari to the United States Court of Appeals for the Second Circuit. Petition for writ of certiorari granted. Judgment vacated, and case remanded to the United States Court of Appeals for the Second Circuit for further consideration in light of Universal Health Services, Inc. v. United States ex rel. Escobar, 579 U.S. ----, 136 S.C

KATZMANN, Chief Judge: At the heart of the case before us is the False Claims Act (“FCA”), which forbids “knowingly presenting], or causing] to be presented, a false or fraudulent claim for payment or approval” to the United States government. 31 U.S.C. § 3729(a)(1)(A). In 2011, Robert Kraus and Paul Bishop (together, the “relators”) brought a qui tam action under the FCA on behalf of the United States against Wells F

It is common practice among district judges in this circuit to make such a statement and adopt the magistrate judges' recommended dispositions when they find that magistrate judges have dealt with the issues fully and accurately and that they could add little of value to that analysis. We cannot interpret the district court's statement as establishing that it failed to perform the required de novo review. In re Griego<

HIGGINBOTHAM, J. ¶ 1. These are appeals of a circuit court order approving a rehabilitation plan of the segregated account of Ambac Assurance Corporation (Ambac) and other court orders entered earlier in this proceeding.2 Numerous interested parties challenge the validity of various provisions of the rehabilitation plan on various grounds as well as actions taken by the Office of the Commissioner of I

Petition for writ of certiorari to the United States Court of Appeals for the Third Circuit denied.