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113616P.pdf   08/22/2013  WFC Holdings Corporation  v.  United States
   U.S. Court of Appeals Case No:  11-3616
   U.S. District Court for the District of Minnesota - Minneapolis   
   [PUBLISHED] [Smith, Author, with Wollman and Murphy, Circuit Judges] 
   Civil case - Federal Tax. Judgment of the district court, which held WFC 
   was not entitled to a tax refund for a capital loss it claimed as a result 
   of a complex transfer of leases and the sale of stock, is affirmed as WFC 
   failed to adequately show that the transaction had either objective 
   economic substance or a subjective, non-tax business purposes.