305 F.3d 976 UNIONBANCAL CORPORATION, f.k.a. Union Bank, Successor in Interest to Standard Chartered Holdings, Inc. and Includable Subsidiaries, Petitioner,v.COMMISSIONER OF INTERNAL REVENUE, Respondent. No. 00-70764. United States Court of Appeals, Ninth Circuit. Argued and Submitted December 4, 2001. Filed September 18, 2002. Frederick R. Chilton, Jr., Paolo M. Dau, and Ward S. Connelly (on […]