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June 9 —The U.S. Supreme Court declined to review a decision by a federal appeals court that affirmed the disallowance by the Internal Revenue Service of a $423 million capital loss claimed by a subsidiary of Wells Fargo & Co. on the basis that the underlying transaction lacked economic substance (WFC Holdings Corp. v. United States, U.S., No. 13-1037, cert. denied 6/9/14).
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