Salem Financial, Inc. v. United States

Tax Refund Suit; STARS Structured Transaction Between BB & T Bank and Bar-clays Bank; Rule 59(e) Motion to Alter or Amend the Court’s Judgment.

OPINION AND ORDER ON PLAINTIFF’S MOTION TO ALTER OR AMEND JUDGMENT

WHEELER, Judge.

On September 20, 2013, the Court issued its post-trial Opinion and Order denying Plaintiffs claim for a tax refund, holding that BB & T Bank1 was not entitled to foreign tax credits, interest expense deductions, or transaction cost deductions claimed in connection with its participation in a financial transaction known as STARS (“Structured Trust Advantaged Repackaged…