The appellants now have 90 … Read More]]>
As evidenced by our prior reports, this case has a long history that now encompasses a Supreme Court opinion and three decisions by the Eleventh Circuit. To recap, the summoned parties sought an evidentiary hearing at which they could examine … Read More]]>
The court of appeals will issue a briefing … Read More]]>
Sanmina claimed a $503 million worthless stock deduction on its return. To support its return position, Sanmina provided the IRS a valuation report prepared by outside counsel DLA Piper. … Read More]]>
Oral argument is tentatively scheduled for the last week in February.
Clarke – Appellants Reply Brief in CA11… Read More]]>
As we noted previously, the government will be motivated to appeal this decision both because of its specific impact … Read More]]>