Fed. Circ. Sinks $115M Wells Fargo Credit For SILO Use
The U.S. Court of Appeals for the Federal Circuit upheld the U.S. Court of Federal Claims' ruling that Wells Fargo was not entitled to a tax refund because the SILO transactions in question were abusive tax shelters, Judge William Bryson wrote for the court.
A SILO transaction occurs when a tax-exempt...
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