Wells Fargo & Co. 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.

• stating that “the characterization of transactions for tax purposes” is a legal issue that is “based on underlying findings of fact” (citation omitted)
• affirming trial court’s denial of interest deduction because the debt was not genuine debt but “existed only on a balance sheet”
• affirming the trial court’s finding that ”[T]he SILO transactions had no effect on the tax-exempt entities’ use of the assets____”
• affirming trial court’s denial of interest deduction because the debt was not genuine debt but “existed only on a balance sheet”
• describing certain amendments to the IRC from 1981 through 2004 which adjusted statutory provisions to address the evolving concerns of Congress
• sustaining the trial court's conclusion that the SILO transactions ran afoul of the substance over form doctrine

Source: CourtListener parenthetical corpus (CC0).