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WELLS FARGO & COMPANY v. U.S.

Misc. No. 10-57 (JRT/JJG).

WELLS FARGO & COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

United States District Court, D. Minnesota.

July 20, 2011.

Attorney(s) appearing for the Case

Andrew T. Gardner and Mark A. Hager , WELLS FARGO & COMPANY, 90 South Seventh Street, Minneapolis, MN 55479; Derek Ho and Reid M. Figel , KELLOGG, HUBER, HANSEN, TODD, EVANS & FIGEL, 1615 M Street Northwest, Suite 400, Washington, DC 20036; Martin S. Chester and Walter A. Pickhardt , FAEGRE & BENSON LLP, 90 South Seventh Street, Suite 2200, Minneapolis, MN 55402-3901, for plaintiff;

James C. Strong and Robert J. Kovacev , UNITED STATES DEPARTMENT OF JUSTICE, TAX DIVISION, Benjamin Franklin Station, Post Office Box 55, Washington, DC 20044, for defendant;

Richard P. Bress , LATHAM & WATKINS LLP, 555 Eleventh Street Northwest, Suite 1000, Washington, DC 20004-1304; Robert Malionek , LATHAM & WATKINS LLP, 885 Third Ave, New York, NY 10022-4834; Steve W. Gaskins , GASKINS, BENNETT, BIRRELL, SCHUPP, LLP, 333 South Seventh Street, Suite 2900, Minneapolis, MN 55402, for amicus curiae Association of Corporate Counsel;

Bruce E. Clark and Jennifer Sheinfeld Goodfellow , SULLIVAN & CROMWELL LLP, 125 Broad Street, New York, NY 10004; Sarah E. Bushnell and Timothy D. Kelly , KELLEY AND HANNAH, PA, 80 South Eighth Street, Suite 3720, Minneapolis, MN 55402, for amicus curiae The Clearing House Association LLC.

ORDER

JOHN R. TUNHEIM, District Judge.

The Court has received simultaneous briefing from Wells Fargo & Company ("Wells Fargo") and the government on the issue of which party bears the burden of proof at the evidentiary hearing scheduled on July 25, 2011. The Internal Revenue Service ("IRS") issued a summons for certain tax accrual work papers ("TAWs") from Wells Fargo which Wells Fargo moved to quash.1 Wells Fargo asserts...

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