The BANK OF NEW YORK MELLON CORPORATION, as Successor in Interest to The Bank of New York Company, Inc., Petitioner-Appellant-Cross-Appellee,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.
American International Group, Inc., Plaintiff-Appellant,
v.
United States of America, Defendant-Appellee.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Martin S. Kaufman , Larchmont, NY, for Amicus Curiae Atlantic Legal Foundation.
Before: CABRANES, RAGGI, and CHIN, Circuit Judges.
CHIN, Circuit Judge:
These appeals and cross-appeal, heard in tandem, challenge an opinion and order of the United States District Court for the Southern District of New York (Stanton, J.) and a judgment of the United States Tax Court (Kroupa, J.) applying the "economic substance doctrine...
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