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...

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