Salem Financial, Inc. v. United States

In the United States Court of Federal Claims No. 10-192T (Filed: September 20, 2013) *********************************** * * SALEM FINANCIAL, INC., * Tax Refund Suit; STARS Structured * Transaction Between BB&T Bank and Plaintiff, * Barclays Bank; Availability of Foreign * Tax Credits From Payment of United v. * Kingdom Taxes; Deductions for Interest * and Transaction Costs; Economic UNITED STATES, * Substance Doctrine Applied to Trust * and Loan Components of Transaction; Defendant. * Assessment of Penalties. * *********************************** * Rajiv Madan, with whom were John B. Magee,…