Wells Fargo Can't Say Docs Are Privileged In $164M IRS Row
Law360, New York (June 17, 2014, 6:30 PM EDT) -- A Minnesota federal judge has denied Wells Fargo & Co.'s claim that certain communication pertaining to a $1.25 billion structured trust advantaged repackaged securities, or STARS, transaction may be excluded as privileged from the bank's $164 million refund suit against the Internal Revenue Service.
U.S. District Judge Patrick J. Schiltz ruled Monday that Special Master Charles Gustafon did not overstep his authority in a Dec. 6 order finding that documents produced by the bank were not privileged under the federally authorized tax practitioners privilege, independent of a specially appointed U.S. Department of Justice attorney.
Federal law extends to some communications between...
Stay ahead of the curve
In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.
Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
Create custom alerts for specific article and case topics and so much more!