U.S. v. SANMINA CORP.

No. 18-17036.

968 F.3d 1107 (2020)

UNITED STATES of America, Petitioner-Appellee, v. SANMINA CORPORATION and Subsidiaries, Respondent-Appellant.

United States Court of Appeals, Ninth Circuit.

Filed August 7, 2020.


Attorney(s) appearing for the Case

Michael C. Lieb (argued) and Leemore L. Kushner , Ervin Cohen & Jessup LLP, Beverly Hills, California, for Respondent-Appellant.

Bethany B. Hauser (argued) and Deborah K. Snyder , Attorneys; Richard E. Zuckerman , Principal Deputy Assistant Attorney General; Tax Division, United States Department of Justice, Washington, D.C.; for Petitioner-Appellee.

Before: Johnnie B. Rawlinson and Consuelo M. Callahan, Circuit Judges, and Susan R. Bolton, District Judge.


OPINION

Sanmina Corporation ("Sanmina") claimed a worthless stock deduction on its federal tax return, which triggered an audit by the United States Internal Revenue Service ("IRS") of Sanmina's tax returns. To support the deduction, Sanmina provided to the IRS a valuation report that had been prepared by DLA Piper...

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