On August 27, 2010, the SEC charged two former Dell executives with fraud for their alleged misconduct relating to the use of the company’s excess tax reserves. SEC v. Davis, Docket No. 1:10-cv-01464 (D.D.C.); SEC v. Imhoff, Docket No. 1:10-cv-01465 (D.D.C.). The SEC’s complaint alleges that Dell improperly used “cookie jar” reserves to…