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IES Industries, Inc. v. United States
United States Court of Appeals for the Eighth Circuit
253 F.3d 350 (8th Cir. 2001)
IES Industries, Inc. (IES) (plaintiff), a United States corporation, purchased a foreign tax credit from a pension fund through a securities broker. IES obtained the tax credit by purchasing stock in the pension fund after a dividend subject to foreign income tax was declared. IES then resold the stock at a loss, with the purchaser paying IES’s foreign tax obligation. IES claimed the foreign tax credit and a capital loss on the stock and used the loss to offset unrelated capital gains. The series of transactions ultimately led to tax savings for IES. IES sought a tax refund based on the trades, and the United States government (defendant) held that the transactions were a sham that should be disregarded for tax purposes. The government filed a motion for summary judgment, which the district court granted. IES appealed.
Rule of Law
Holding and Reasoning (Bowman, J.)
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