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173578P.pdf   04/24/2020  Wells Fargo & Company  v.  United States
   U.S. Court of Appeals Case No:  17-3578
   U.S. District Court for the District of Minnesota - Minneapolis   
[PUBLISHED] [Shepherd, Author, with Grasz and Kobes, Circuit Judges] Civil case - Federal tax. The district court did not err in determining Wells Fargo was not entitled to a tax credit on its 2003 return arising out of a transaction between Wells Fargo and a British Bank; nor did the court err in determining Wells Fargo was liable for a negligence penalty after claiming that credit. Judge Grasz, dissenting in part.