Legal Opinion
Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United States
Court of Appeals for the Federal Circuit
Decided May 14, 2015No. 2014-5027PublishedCited by 15 opinions
1Opinion of the Court
BRYSON, Circuit Judge.
Salem Financial, Inc., a subsidiary of Branch Banking & Trust Corporation (“BB & T”), challenges a final judgment of the Court of Federal Claims denying BB & T’s claim for a refund of taxes, interest, and penalties. We affirm in part, reverse in part, and remand for further proceedings.
I
A
BB & T is a financial holding company chartered under the laws of North Carolina. In 2002, BB & T entered into a transaction with Barclays Bank PLC (“Barclays”), which is headquartered in the United Kingdom. The transaction, known as the Structured Trust Advantaged Repackaged Securities…
2Cases cited38 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
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3Cited by15 opinions
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- Wells Fargo & Company v. United StatesCourt of Appeals for the Eighth Circuit · 2020
- Wells Fargo & Co. v. United StatesDistrict Court, D. Minnesota · 2015
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