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]]>
The panel consisted of Judge Lourie and the two most recent appointments to the Federal Circuit, Judges Hughes and Stoll. Although Judge Lourie was silent during the argument, the latter two judges posed questions of both sides. Both of those judges expressed skepticism of the government’s position … Read More]]>