TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Wednesday, October 5, 2011

DOJ Wins Three Tax Shelter Cases on Same Day

DOJ Logo Department of Justice Press Release, Justice Department Prevails in Three Tax Shelter Cases on Same Day: Federal Courts Deny Hundreds of Millions in Tax Breaks to Billionaire Dallas Banker, Principal Life Insurance Co. and Wells Fargo & Co. (Oct. 4, 2011):

Three federal courts have issued decisions in favor of the United States in three separate cases involving abusive tax shelters, the Justice Department announced today.  All of the court opinions were issued on Sept. 30, 2011.

  • In Southgate Master Fund LLC v. United States, the U.S. Court of Appeals for the Fifth Circuit, based in New Orleans, affirmed a lower court ruling that a company formed by billionaire Dallas banker D. Andrew Beal and others was a sham partnership that must be disregarded for federal income tax purposes. ...
  • In Pritired 1 LLC v. United States, Judge John A. Jarvey of the U.S. District Court for the Southern District of Iowa prohibited Principal Life Insurance Co. from claiming more than $20 million in foreign tax credits that the company had sought based on a complex transaction involving a $300 million payment to two French banks. ...
  • Finally, in WFC Holdings Corporation v. United States, Judge John R. Tunheim of the U.S. District Court for the District of Minnesota disallowed a tax refund claim for more than $80 million filed by a subsidiary of Wells Fargo & Co.

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Tracked on Oct 5, 2011 6:19:37 AM