United States v. Woods

United States v. Woods

Argued October 9, 2013
Decided December 3, 2013
Full case name United States, Petitioner v. Gary Woods
Docket nos. 12-562
Citations

571 U.S. ___ (more)

Argument Oral argument
Opinion announcement Opinion announcement
Prior history Petitioners request granted, US Dis. Ct.; District Court affirmed by 5th Ckt. Ct.
Holding
The district court had jurisdiction to determine whether the partnerships’ lack of economic substance could justify imposing a valuation-misstatement penalty on the partners.
Court membership
Case opinions
Majority Scalia, joined by unanimous
Laws applied
Tax Equity and Fiscal Responsibility Act of 1982

United States v. Woods, 571 U.S. ___ (2013), was a United States Supreme Court case in which the Court addressed whether district courts have jurisdiction regarding provisions of the Internal Revenue Service Code and its implementation.[1] The court held unanimously that a district court has jurisdiction in the application of the Internal Revenues Service Code to a partnership-level proceeding when it is applied to that partnership. The court additionally found that a transaction determined to lack economic substance can still trigger the penalty for overstatement because the overstatement and the action that led to it are inherently tied together.[2]

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