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UNIONBANCAL CORP. v. C.I.R.

No. 00-70764.

305 F.3d 976 (2002)

UNIONBANCAL CORPORATION, f.k.a. Union Bank, Successor in Interest to Standard Chartered Holdings, Inc. and Includable Subsidiaries, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Ninth Circuit.

Filed September 18, 2002.

Attorney(s) appearing for the Case

Frederick R. Chilton, Jr., Paolo M. Dau, and Ward S. Connelly (on the brief), Paulo Dau (argued), Fenwick & West LLP, Palo Alto, CA, for the petitioner.

Jonathan S. Cohen and Charles Bricken (on the brief), Charles Bricken (argued), Department of Justice, Tax Division, Washington, DC, for the respondent.

Before BRUNETTI, KLEINFELD and THOMAS, Circuit Judges.

Opinion by Judge KLEINFELD; Dissent by Judge THOMAS.

KLEINFELD, Circuit Judge.

This is a tax case regarding availability of a loss deduction to a company whose predecessor-in-interest left a "controlled group."1

FACTS

The facts are undisputed, because the parties stipulated to them before the Tax Court, but the details are complex. Here is a simplified summary. The Appellant, UnionBanCal, is the successor-in-interest...

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