Editor's Note :

Editor's Note :

In previous years, the Court released orders the morning after the Court’s “Long Conference.” It has not done so this year. Beginning last Term, the Court consistently considered petitions at least two times before granting certiorari. To the extent that practice continues -- and there is no affirmative evidence the Court intends to drop it -- we would not expect orders granting certiorari today.

WFC Holdings Corporation v. United States

Petition for certiorari denied on June 9, 2014
Docket No. Op. Below Argument Opinion Vote Author Term
13-1037 8th Cir. N/A N/A N/A N/A OT 2013

Issue: Whether an objectively profitable transaction can be disregarded for tax purposes under the judge-made economic substance doctrine because it was structured to achieve income tax deductions authorized by the plain language of the Internal Revenue Code.

DateProceedings and Orders
Jan 15 2014Application (13A757) to extend the time to file a petition for a writ of certiorari from January 27, 2014 to February 26, 2014, submitted to Justice Alito.
Jan 20 2014Application (13A757) granted by Justice Alito extending the time to file until February 26, 2014.
Feb 14 2014Application (13A757) to extend further the time from February 26, 2014 to March 28, 2014, submitted to Justice Alito.
Feb 18 2014Application (13A757) denied by Justice Alito.
Feb 26 2014Petition for a writ of certiorari filed. (Response due March 31, 2014)
Mar 4 2014Consent to the filing of amicus curiae briefs, in support of either party or neither party, received from counsel for petitioner.
Mar 14 2014Brief amicus curiae of Professor Amandeep S. Grewal filed.
Mar 26 2014Order extending time to file response to petition to and including April 30, 2014.
Mar 28 2014Brief amici curiae of American Bankers Association, et al. filed.
Mar 31 2014Brief amici curiae of Cato Institute, et al. filed.
Mar 31 2014Brief amici curiae of Private Practioners filed.
Mar 31 2014Brief amicus curiae of Alston & Bird LLP filed.
Mar 31 2014Brief amicus curiae of Atlantic Legal Foundation filed.
Mar 31 2014Brief amicus curiae of Center for Fair Administration of Taxes filed.
Mar 31 2014Brief amici curiae of Reiss+Preuss LLP, and Tax Students filed.
Mar 31 2014Brief amicus curiae of Givner & Kaye APC filed.
Apr 30 2014Brief of respondent United States in opposition filed.
May 20 2014DISTRIBUTED for Conference of June 5, 2014.
May 20 2014Reply of petitioner WFC Holdings Corporation filed. (Distributed)
Jun 9 2014Petition DENIED.
 
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