Wells Fargo Rejected by U.S. High Court on $148 Million Tax Bid

(Bloomberg) The U.S. Supreme Court turned away a Wells Fargo & Co. unit’s bid for as much as $148 million in tax refunds, leaving intact an Internal Revenue Service victory in a corporate tax-shelter case.

The justices today let stand a federal appeals court’s conclusion that a disputed transaction involving leases and stock lacked any economic substance. The panel said the IRS was justified in rejecting hundreds of millions of dollars in paper losses generated by the transaction.

Wells Fargo’s WFC Holdings unit argued unsuccessfully that the lease restructuring produced tens of millions of dollars in economic benefits for the company and its shareholders.

The appeal had backing from the U.S. Chamber of Commerce and the American Bankers Association.

The case is WFC Holdings v. United States, 13-1037.

For reprint and licensing requests for this article, click here.
Tax practice
MORE FROM ACCOUNTING TODAY