Fed. Circ. Sinks $115M Wells Fargo Credit For SILO Use

Law360, New York (April 15, 2011, 6:18 PM EDT) -- The Federal Circuit on Friday denied Wells Fargo & Co.'s $115 million tax deduction for the 2002 tax year, ruling the company had wrongly used a type of arrangement known as a sale-in, lease-out transaction.

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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