Legal Opinion

Sovereign Bancorp, Inc. v. United States

District Court, D. Massachusetts

Decided July 17, 2018No. 1:09-cv-11043Unknown

1Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS CIVIL ACTION NO. 09-11043-GAO SANTANDER HOLDINGS USA, INC. & SUBSIDIARIES, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. OPINION AND ORDER July 17, 2018 O’TOOLE, D.J. The plaintiff, Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc. (“Sovereign”), filed this suit to recover approximately $234 million in federal taxes, penalties, and interest that were assessed and collected by the Internal Revenue Service (“IRS”) in connection with Sovereign’s “Structured Trust Advantaged Repackaged Securities” (“STARS”)…

2Cases cited20 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
  3. Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner, in No. 97-7484 v. Commissioner of Internal Revenue Acm Partnership, Southampton-Hamilton Company, Tax Matters Partner v. Commissioner of Internal Revenue, in No. 97-7527Court of Appeals for the Third Circuit · 1998
  4. Klamath Strategic Investment Fund Ex Rel. St. Croix Ventures v. United StatesCourt of Appeals for the Fifth Circuit · 2009
  5. David Dewees and Anne Dewees v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1989

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