Bb&t Corp. v. United States

Affirmed by published opinion. Chief Judge WILLIAMS wrote the opinion, in which Judge WILKINSON and Judge DUFFY joined.

OPINION

WILLIAMS, Chief Judge:

This appeal requires us to determine the tax consequences of a complex financial transaction. BB & T Corp. entered into a “lease-in/lease-out” transaction, often called a “LILO,” hoping to reduce its tax liability, but the Internal Revenue Service (“IRS”) disallowed the deductions it claimed. After BB & T sued for a refund, the district court granted summary judgment in favor of the Government.

BB & T now appeals, arguing that the district court…