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Jack Townsend on the Wells Fargo SILO deals shot down in the Court of Federal Claims last week:
I don't think that these transactions are materially different than the transactions involved in the KPMG prosecutions; indeed at some level they may be worse. As I have said, criminal tax cases are all about the lie. And, there appears to have been lies in these transactions.
And that's the nicest thing he has to say about the deals.
Prior Tax Update Coverage: Bureaucrat vs. Bureaucrat
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