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WFC HOLDINGS CORP. v. U.S.

No. 11-3616.

728 F.3d 736 (2013)

WFC HOLDINGS CORPORATION, Plaintiff-Appellant v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: August 22, 2013.

Attorney(s) appearing for the Case

Derek T. Ho , argued, Washington, DC ( Christopher Klimmek , Washington, DC, Philip Karter , Herbert Odell and Jonathan M. Prokup , West Conshohocken, PA, and Mark A. Hager and Jeffrey Sloan , on the brief, Minneapolis, MN), for Appellant.

Judith Ann Hagley , of USDOJ, Tax Division, argued, Washington, DC ( Gilbert Steven Rothenberg , of USDOJ, Tax Division, on the brief, Washington, DC), for Appellee.

Before WOLLMAN, MURPHY, and SMITH, Circuit Judges.

SMITH, Circuit Judge.

WFC Holdings Corporation (WFC) appeals from the judgment of the district court,1 which held that WFC is not entitled to a tax refund for a capital loss it claimed as a result of a complex transaction involving the transfer of leases and the sale of stock. We hold that WFC failed to adequately show that the transaction had either objective economic substance or a subjective, non-tax business purpose, and we affirm...

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