Federal judge Thomas C. Wheeler issued a scathing characterization of the parties in the tax shelter case, as Structured Trust Advantaged Repackaged Securities. Wheeler rejected the claim of a subsidiary of the BB&T Corp. that it was entitled to $660 million in tax benefits via the Stars shelter, and imposed $112 million in penalty.Wheeler, a judge for the Court of Federal Claims in Washington, D.C., labeled the behavior of the parties in Stars as "nothing short of reprehensible," and that the effort put into the transaction was a "waste of human potential."
The parties were Barclays Bank and KMPG , which joint developed and marketed the Stars transaction. The Internal Revenue Service sought to quash the shelters, saying they were a way to "subvert the foreign tax credit rules and generate illicit tax benefits to be shared among the transaction's participants. "
Wheeler's comdemnation applied to Barclays, KPMG, BB&T, as well as law firm, Sidley & Austin, which was hired by BB&T to provide tax advice to support the transaction