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WELLS FARGO & CO. v. U.S.

No. 17-3578.

957 F.3d 840 (2020)

WELLS FARGO & COMPANY, on behalf of itself and the members of its affiliated group filing a consolidated return Plaintiff-Appellant, v. UNITED STATES of America Defendant-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: April 24, 2020.

Attorney(s) appearing for the Case

Deborah Ann Ellingboe , Walter A. Pickhardt , Charles F. Webber , Faegre & Drinker, Jeffrey A. Sloan , Wells Fargo & Company, Minneapolis, MN, Alan Swirski , Nathan P. Wacker , B. John Williams, Jr. , Skadden & Arps, Washington, DC, for Plaintiff-Appellant.

Dennis M. Donohue , Judith Ann Hagley , U.S. Department of Justice, Tax Division, Matthew Steven Johnshoy , Gilbert Steven Rothenberg , Senior Attorney, U.S. Department of Justice, Tax Division, Appellate Section, Harris Phillips , Trial Attorney, U.S. Department of Justice, Tax Division, Civil Trial Section, Central Region, Washington, DC, for Defendant-Appellee.

Before SHEPHERD, GRASZ, and KOBES, Circuit Judges.

Wells Fargo & Company (Wells Fargo) appeals from the district court's1 determination that it was not entitled to a tax credit on its 2003 tax return arising from a transaction that Wells Fargo entered into with a British bank. It also appeals from the court's determination that Wells Fargo...

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