Legal Opinion
Santander Holdings USA, Inc. & Subsidiaries v. United States
District Court, D. Massachusetts
Decided October 17, 2013No. Civil Action No. 09-11043-GAOPublishedCited by 8 opinions
1Opinion of the Court
OPINION
O’TOOLE, District Judge.
Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc., and referred to in this opinion as “Sovereign,” has sued to recover approximately $234 million in federal income taxes, penalties, and interest that it claims were improperly assessed and collected by the Internal Revenue Service for tax years 2003, 2004, and 2005 as a consequence of the IRS’s disallowance of foreign tax credits claimed by Sovereign for those years. The United States defends the disallowance on the ground that the transaction in which Sovereign incurred and paid the foreign…
2Cases cited17 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Kerry W. Illes v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1992
- Stephen A. Mahoney, Iii, and Mary Ann Mahoney v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1987
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3Cited by8 opinions
- Santander Holdings USA, Inc. v. United StatesCourt of Appeals for the First Circuit · 2016
- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
- Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2015
- Wells Fargo & Company v. United StatesCourt of Appeals for the Eighth Circuit · 2020
- Wells Fargo & Co. v. United StatesDistrict Court, D. Minnesota · 2015
3 more not listed; retrieve them via the Exa API.