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WFC Holdings Corporation v. United States

Certiorari Denied

Petition for certiorari denied on June 9, 2014.

Docket No.13-1037
Op. Below8th Cir.

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.

Proceedings & orders timeline

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.

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