Mary Mcnulty Quoted On Court Of Federal Claims Decision In Interest Netting Case


Mary McNulty was quoted in a Tax Notes Today article (subscription required) on the Court of Federal Claims decision in Wells Fargo.  In Wells Fargo, the Court of Federal Claims found that a taxpayer may net underpayment balances and overpayment balances among merged entities because the acquiring corporation becomes one and the same with the target corporation by operation of law. 

As we discussed in a prior post, this decision is very significant because the court’s reasoning presents a strong case for extending the holding to other situations such as liquidations and acquisitions when the acquiring corporation legally assumes the target’s tax liabilities, whether by operation of law or contractually. 


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