Legal Opinion
Wells Fargo & Co. And Subsidiaries v. United States
Court of Appeals for the Federal Circuit
Decided April 15, 2011No. 2010-5108PublishedCited by 30 opinions
1Opinion of the Court
BRYSON, Circuit Judge.
This case requires us to evaluate the federal income tax consequences of sale-in, lease-out (“SILO”) transactions. The Court of Federal Claims denied Wells Fargo $115 million in claimed deductions for tax year 2002 stemming from its partic ipation in 26 SILO transactions with tax-exempt entities. We affirm.
I
A sale-in, lease-out transaction of the sort at issue in this case consists of two concurrent leases of an asset owned by a tax-exempt entity. In the first lease, known as the “head lease,” the tax-exempt entity leases the asset to the taxpayer for a lease term that…
2Cases cited15 opinions
- Corliss v. BowersSupreme Court of the United States · 1930
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Griffiths v. CommissionerSupreme Court of the United States · 1939
- Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938
10 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Southgate Master Fund, L.L.C. Ex Rel. Montgomery Capital Advisors, LLC v. United StatesCourt of Appeals for the Fifth Circuit · 2011
- Altria Group, Inc. v. United StatesCourt of Appeals for the Second Circuit · 2011
- Summa Holdings v. Comm'r of Internal RevenueCourt of Appeals for the Sixth Circuit · 2017
- Consolidated Edison Co. of New York, Inc. & Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 2013
- John Hancock Life Ins. Co. (U.S.A.) v. Comm'rUnited States Tax Court · 2013
25 more not listed; retrieve them via the Exa API.