Wachovia pursues claims against IRS for failing to pay full tax refund under interest netting rules

Client(s) Wachovia Corporation

Jones Day represented Wachovia Corporation in a suit alleging that the IRS failed to pay Wachovia the full tax refund to which it was entitled for certain tax years. The case involves the IRS's application of interest netting rules that apply to overlapping periods of tax overpayments and underpayments. The case settled prior to trial, with the government agreeing to pay Wachovia the full amount of the refund that it claimed.

Wachovia Corp. v. United States, No. 1:07-cv-00118-MBH (Ct. Fed. Cl.)