Wells Fargo & Co. & Subsidiaries v. United States

OPINION AND ORDER

WHEELER, Judge.

In this tax refund suit, Plaintiff Wells Fargo & Company (“Wells Fargo”) claims $115,174,203.00 in depreciation, interest and transaction cost deductions for the tax year 2002. The deductions stem from Wells Fargo’s participation in 26 leveraged lease transactions, seventeen with domestic transit agencies, and nine involving qualified technological equipment (“QTE”). Although the tax treatment of all 26 transactions is at issue in this case, the parties limited their trial *37presentation to five agreed transactions, allowing the Court’s ruling on these five to…