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SANTANDER HOLDINGS USA, INC. v. U.S.

CIVIL ACTION NO. 09-11043-GAO.

144 F.Supp.3d 239 (2015)

SANTANDER HOLDINGS USA, INC. & Subsidiaries, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Massachusetts.

Signed November 13, 2015.

Attorney(s) appearing for the Case

Christopher Bowers , Christopher P. Murphy , Rajiv Madan , Royce Tidwell , Nathan P. Wacker , Skadden, Arps, Slate, Meagher & Flom LLP, John Magee , Bingham McCutchen LLP, Washington, DC, Deana K. El-Mallawany , U.S. Attorney's Office, James C. McGrath , Seyfarth Shaw LLP, Boston, MA, for Plaintiff.

Alan S. Kline , John L. Schoenecker , Raagnee Beri , William E. Farrior , U.S. Department of Justice, Dennis M. Donohue , Washington, DC, for Defendant.

OPINION AND ORDER

Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc., and referred to in this opinion as "Sovereign," has sued to recover approximately $234 million in federal income taxes, penalties, and interest that it claims were improperly assessed and collected by the Internal Revenue Service for...

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