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Professional Responsibility Keyed to Sahl
Schaeffler v. United States (I)
Citation:806 F.3d 34 (2d Cir. 2015)
The Schaeffler Group (Petitioner) found a consortium of banks to loan it 11 billion euros for an acquisition. After the 2008 economic crisis, it refinanced the acquisition debt and restructured the group, which affected its personal tax liability to the IRS. It hired a law firm to advise it on federal tax implications. However, the group received an IRS summons for tax documents related to the acquisition, which it moved to quash.
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