Wells Fargo & Company v. United States of America
Plaintiff: Wells Fargo & Company
Defendant: United States of America
Case Number: 0:2009cv02764
Filed: October 5, 2009
Court: US District Court for the District of Minnesota
Office: DMN Office
County: Hennepin
Presiding Judge: Boylan
Presiding Judge: Schiltz
Nature of Suit: Other
Cause of Action: 26 U.S.C. ยง 7422 IRS: Refund Taxes
Jury Demanded By: None

Available Case Documents

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Date Filed Document Text
February 5, 2018 Opinion or Order Filing 686 ORDER denying 673 Motion for Judgment as a Matter of Law or in the alternative Motion for New Trial. (Written Opinion) Signed by Judge Patrick J. Schiltz on February 5, 2018. (CLG)
September 15, 2017 Opinion or Order Filing 665 ORDER re 657 Briefing Order. Plaintiff is not entitled to deduct the foreign tax payments that it made in connection with the STARS transaction. The parties must submit their proposed form of judgment to the Court no later than September 25, 2017. No extension of this deadline will begranted. (Written Opinion). Signed by Judge Patrick J. Schiltz on 9/15/2017. (ECW)
May 24, 2017 Opinion or Order Filing 650 ORDER. IT IS HEREBY ORDERED THAT: 1. Plaintiff is entitled, under 26 U.S.C. § 163(a), to deduct the interest expenses associated with the loan that was part of the STARS transaction. 2. Plaintiff is subject to the negligence penalty under 26 U.S.C. § 6662(b)(1) for the underpayments associated with the foreign-tax credits that it claimed in its reporting of the STARS transaction. 3. The parties are directed to meet and confer on a proposed form of judgment incorporating these rulings. The parties must submit their proposal to the Court no later than June 30, 2017.(Written Opinion). Signed by Judge Patrick J. Schiltz on May 24, 2017. (CLG)
July 22, 2014 Opinion or Order Filing 486 REPORT OF SPECIAL MASTER. (Written Opinion). Signed by Special Master Charles H. Gustafson on July 21, 2014. (CLG) cc: Charles Gustafson on 7/22/2014 (JAM).
June 16, 2014 Opinion or Order Filing 480 ORDER - Plaintiff's objection 440 is OVERRULED. The special master's orders and report ECF Nos. 434 , 435 , 438 are AFFIRMED and ADOPTED. (Written Opinion). Signed by Judge Patrick J. Schiltz on 06/16/14. (BJS)
September 11, 2013 Opinion or Order Filing 373 ORDER - Plaintiff's objection 342 is OVERRULED. The special master's order and report 337 , 338 are AFFIRMED and ADOPTED. (Written Opinion). Signed by Judge Patrick J. Schiltz on 09/11/13. (BJS) cc: Special Master. Modified on 9/11/2013 (GMW).
May 28, 2013 Opinion or Order Filing 325 ORDER denying 281 Motion to Exclude Expert Testimony (Written Opinion). Signed by Special Master Charles H. Gustafson on May 27, 2013. (clg)
August 10, 2012 Opinion or Order Filing 256 ORDER - Plaintiff's objection 227 is OVERRULED. The special master's order and report 222 are AFFIRMED and ADOPTED. Plaintiffs motion for partial summary judgment 149 is DENIED. (Written Opinion). Signed by Judge Patrick J. Schiltz on 08/10/12. (bjs) CC: Charles H. Gustafson on 8/10/2012 (MMP).
December 16, 2011 Opinion or Order Filing 208 ORDER adopting Special Master Report and Recommendation 193 . The time for objections having expired, IT IS HEREBY ORDERED THAT the October 31, 2011 report and order are AFFIRMED. Signed by Judge Patrick J. Schiltz on 12/16/11. (sf) (cc: Charles H. Gustafson on 12/16/2011 (MMP).
October 27, 2010 Opinion or Order Filing 56 ORDER - Based on the foregoing, and on all of the files, records, and proceedings herein, IT IS HEREBY ORDERED that plaintiff's objection 52 to Judge Boylans July 15, 2010 Order 51 is OVERRULED and the Order is AFFIRMED.Signed by Judge Patrick J. Schiltz on 10/27/10. (Written Opinion). (bjs)
July 15, 2010 Opinion or Order Filing 51 ORDER denying 37 Motion to Strike (Written Opinion). Signed by Magistrate Judge Arthur J. Boylan on 7/15/10. (kt)
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Plaintiff: Wells Fargo & Company
Represented By: William K Wilcox
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Defendant: United States of America
Represented By: Matthew-NA Von Schuch
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