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WELLS FARGO & CO. v. U.S.

No. 2010-5108.

641 F.3d 1319 (2011)

WELLS FARGO & COMPANY and Subsidiaries, Plaintiff-Appellant, v. UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

April 15, 2011.

Attorney(s) appearing for the Case

David Farrington Abbott , Mayer Brown, LLP, of New York, NY, argued for plaintiff-appellant. With him on the brief were Brian W. Kittle ; and Stephen M. Shapiro , Joel V. Williamson , Thomas C. Durham , Timothy S. Bishop and Michael R. Emerson , of Chicago, IL.

Cory A. Johnson , Attorney, Tax Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee. On the brief were John A. Dicicco , Acting Assistant Attorney General, Richard Farber and Judith A. Hagley , Attorneys.

Before NEWMAN, BRYSON, and LINN, Circuit Judges.

BRYSON, Circuit Judge.

This case requires us to evaluate the federal income tax consequences of sale-in, lease-out ("SILO") transactions. The Court of Federal Claims denied Wells Fargo $115 million in claimed deductions for tax year 2002 stemming from its participation in 26 SILO transactions with tax-exempt entities. We affirm.

I

A sale-in, lease-out transaction of the sort at issue in this case consists...

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