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