Wells Fargo Can't Claim $82M Tax Refund, 8th Circ. Rules

Law360, Los Angeles (August 22, 2013, 6:30 PM ET) -- Wells Fargo & Co. isn’t entitled to an $82 million tax refund for a loss it claimed when it moved real estate it had acquired from a merger into a subsidiary, because the lease moves served no real business purpose, the Eighth Circuit found Thursday.

A three-judge appeals panel affirmed a Minnesota federal judge’s ruling that Wells Fargo can’t claim the tax refund on the grounds the land transfer lacked objective economic substance and a subjective business purpose.

Wells Fargo’s parent company, WFC Holdings Corp., was suing...
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