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WELLS FARGO & CO. v. U.S.

2015-5059.

827 F.3d 1026 (2016)

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

United States Court of Appeals, Federal Circuit.

Decided: June 29, 2016.

Attorney(s) appearing for the Case

GERALD KAFKA , Latham & Watkins LLP, Washington DC, argued for plaintiff-appellee. Also represented by GREGORY G. GARRE , BENJAMIN SNYDER , NICOLLE NONKEN GIBBS .

ELLEN PAGE DELSOLE , Tax Division, United States Department of Justice, Washington, DC, argued for defendant-appellant. Also represented by JONATHAN S. COHEN, GILBERT STEVEN ROTHENBERG , CAROLINE D. CIRAOLO , DIANA L. ERBSEN .

Before LOURIE, HUGHES, and STOLL, Circuit Judges.

The United States appeals from the Court of Federal Claims' order granting Wells Fargo & Company's motion for partial summary judgment and denying the government's motion for partial summary judgment. The court held that Wells Fargo's interest-netting claims under § 6621(d) of the Internal Revenue Code ("I.R.C.")

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