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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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UNITED STATES v. WOODS
Case Documents

1UNITED STATES v. WOODS Oral Argument Transcript (PDF)
2Slip Opinion in UNITED STATES v. WOODS (Opinion by Justice Antonin Scalia)
3UNITED STATES v. WOODS Oral Argument Audio