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SANTANDER HOLDINGS USA, INC. v. U.S.

CIVIL ACTION NO. 09-11043-GAO.

144 F.Supp.3d 239 (2015)

SANTANDER HOLDINGS USA, INC. & Subsidiaries, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Massachusetts.

Signed November 13, 2015.

Attorney(s) appearing for the Case

Christopher Bowers, Christopher P. Murphy, Rajiv Madan, Royce Tidwell, Nathan P. Wacker, Skadden, Arps, Slate, Meagher & Flom LLP, John Magee, Bingham McCutchen LLP, Washington, DC, Deana K. El-Mallawany, U.S. Attorney's Office, James C. McGrath, Seyfarth Shaw LLP, Boston, MA, for Plaintiff.

Alan S. Kline, John L. Schoenecker, Raagnee Beri, William E. Farrior, U.S. Department of Justice, Dennis M. Donohue, Washington, DC, for Defendant.

OPINION AND ORDER

Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc., and referred to in this opinion as "Sovereign," has sued to recover approximately $234 million in federal income taxes, penalties, and interest that it claims were improperly assessed and collected by the Internal Revenue Service for...

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