Legal Opinion
Wells Fargo & Company v. United States
United States Court of Federal Claims
Decided October 20, 2014No. 1:11-cv-00808PublishedCited by 4 opinions
1Opinion of the Court
Tax; Interest Netting under 26 U.S.C. § 6621(d); “Same Taxpayer”; Merged Corporations
AMENDED OPINION
FIRESTONE, Judge.
This case presents an issue of first impression regarding the application of Internal Revenue Code (“I.R.C,” or “Code”) § 6621(d) to corporations that have acquired other corporations or been acquired through a statutory merger. It concerns whether plaintiff, Wells Fargo & Company (“Wells Fargo”), is entitled to net the interest paid on certain tax underpayments owed by Wells Fargo or its predecessor, First Union Corporation (“First Union”), with the interest owed by the United…
2Cases cited10 opinions
- Duncan v. WalkerSupreme Court of the United States · 2001
- John Wiley & Sons, Inc. v. LivingstonSupreme Court of the United States · 1964
- Tcherepnin v. KnightSupreme Court of the United States · 1967
- Commissioner v. HansenSupreme Court of the United States · 1959
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Voss v. CommissionerCourt of Appeals for the Ninth Circuit · 2015
- Ford Motor Company v. United StatesUnited States Court of Federal Claims · 2017
- Bank of America Corporation v. United StatesDistrict Court, W.D. North Carolina · 2023
- Voss v. CommissionerCourt of Appeals for the Ninth Circuit · 2015