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WFC HOLDINGS CORPORATION v. U.S.

Civil No. 07-3320 (JRT/FLN).

WFC HOLDINGS CORPORATION, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

United States District Court, D. Minnesota.

September 30, 2011.

Attorney(s) appearing for the Case

Philip Karter , Jonathan Prokup , and Herbert Odell , CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN, 300 Conshohocken State Road, Suite 570, West Conshohocken, PA; Jeffrey A. Sloan and Mark A. Hager , WELLS FARGO & COMPANY, 90 South Seventh Street, MAC N9305-164, Minneapolis, MN 55479, for plaintiff.

Thomas P. Cole , Gregory E. Van Hoey , and Jacqueline C. Brown , UNITED STATES DEPARTMENT OF JUSTICE, TAX DIVISION, P.O. Box 7328, Ben Franklin Station, Washington, DC, for defendant.

FINDINGS OF FACT, CONCLUSIONS OF LAW, AND ORDER FOR JUDGMENT

JOHN R. TUNHEIM, District Judge.

Plaintiff WFC Holdings Corporation ("WFC" or "Wells Fargo"1) brought this action against the United States seeking a refund of federal income taxes in the amount of at least $82,313,366 for the tax year ending December 31, 1996. (Compl. ¶ 1, Docket No. 1.) According to the government, WFC's refund demand is based on capital losses...

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