Ies Industries, Inc., and Subsidiaries, Alliant Energy Corporation, Successor in Interest to Ies Industries, Inc. And Subsidiaries v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• considering \each trade as a whole\ rather than as separate purchase, payment, and sale transactions, thereby treating refunds for capital-loss carrybacks and taxes owed on foreign dividends as single transaction
• rejecting the argument “Rule 15(b)’s consent requirement is not met where evidence that is relevant to an issue purportedly tried by consent is also relevant to an issue already in the case” because the argument is “an overstatement, if not a misstatement of the law”
• “In order for us to determine, in our first opinion in this case, that the trades were not sham transactions ... we considered each trade as a whole, just as IES asked us to.”

Source: CourtListener parenthetical corpus (CC0).