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UNITED STATES v. WOODS

Docket No.: 12-562
Certiorari Granted: Mar 25 2013
Argued: October 9, 2013
Decided: December 3, 2013

Topic:

judicial review

PartyNames: United States v. Gary Woods
Petitioner: United States
Respondent: Gary Woods

Court Below: United States Court of Appeals for the Fifth Circuit
Citation: 471 Fed. Appx. 320
Supreme Court Docket

United States
v.
Gary Woods
Background:

Section 6662 of the Internal Revenue Code prescribes a penalty for an underpayment of federal income tax that is "attributable to" an overstatement of basis in property. 26 U.S.C. 6662(a), (b)(3), (e)(l)(A) and (h)(l)

Question Presented:

Whether the overstatement penalty applies to an underpayment resulting from a determination that a transaction lacks economic substance because the sole purpose of the transaction was to generate a tax loss by artificially inflating the taxpayer's basis in property.

Note:

IN ADDITION TO THE QUESTION PRESENTED BY THE PETITION, THE PARTIES ARE DIRECTED TO BRIEF AND ARGUE THE FOLLOWING QUESTION: WHETHER THE DISTRICT COURT HAD JURISDICTION IN THIS CASE UNDER 26 U.S.C. ยง6226 TO CONSIDER THE SUBSTANTIAL VALUATION MISSTATEMENT PENALTY CERT. GRANTED 3/25/201312-562 UNITED STATES V. WOODS

UNITED STATES v. WOODS
ORAL ARGUMENT

October 9, 2013

Listen to Oral Argument in UNITED STATES v. WOODS
Holding: REVERSED
Vote: 9-0
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