United States Federal Circuit

In a case involving U.S. tax treatment of several aspects of plaintiff's involvement in the Structured Trust Advantaged Repackaged Securities (STARS) transaction, the Court of Federal Claims' judgment denying plaintiff's claim for a refund of taxes, interest, and penalties is: 1) affirmed in part where he trial court did not err in imposing accuracy-related penalties on plaintiff; and 2) reversed in part where the amount of the penalties requires reassessment, as plaintiff is entitled to claim interest deductions for the interest it paid on the STARS Loan.

Appellate Information

• Decided 05/14/2015
• Published 05/14/2015

Judges

• BRYSON

Court

• United States Federal Circuit

Counsel