Legal Opinion
Salem Financial, Inc. v. United States
United States Court of Federal Claims
Decided January 18, 2012No. 10-192TPublishedCited by 4 opinions
1Opinion of the Court
OPINION AND ORDER ON DEFENDANT’S MOTION TO COMPEL DISCOVERY
WHEELER, Judge.
Background
This case involves the determination of the appropriate tax treatment of a complex transaction known as STARS (“Structured Trust Advantaged Repackaged Securities”). By means of the STARS transaction, Plaintiffs predeeessor-in-interest, Branch Investments LLC (“Branch”) was able to claim foreign income tax credits on its 2002-2007 U.S. tax returns totaling $498,161,951; business expense deductions on its 2002-2007 tax returns; and interest expense deductions on its 2006-2007 U.S. tax returns. See Compl. ¶¶31,…
2Cases cited12 opinions
- Upjohn Co. v. United StatesSupreme Court of the United States · 1981
- United States v. Arthur Young & Co.Supreme Court of the United States · 1984
- United States v. BiscegliaSupreme Court of the United States · 1975
- In Re Sealed CaseCourt of Appeals for the D.C. Circuit · 1984
- American Standard Inc. v. Pfizer Inc. And Howmedica, Inc., and Biomet, Inc.Court of Appeals for the Federal Circuit · 1987
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3Cited by4 opinions
- Oasis International Waters, Inc. v. United StatesUnited States Court of Federal Claims · 2013
- Parker v. Mobile Gas Service Corp.Supreme Court of Alabama · 2013
- Schaeffler v. United StatesDistrict Court, S.D. New York · 2014
- Fairholme Funds, Inc. v. United StatesUnited States Court of Federal Claims · 2017