Judge Schiltz of the U.S. District Court of Minnesota recently issued an opinion in Wells Fargo & Co. v. United States, that qualifies as a key development in the law of economic substance. Taxpayers have battled the government for decades over the precise contours of the judicially-created doctrine often advanced by the government and employed by the courts to deny tax benefits of particular transactions that comply with the strict terms of the Tax Code, but which ... Keep Reading »