Legal Opinion
United States v. Woods
Supreme Court of the United States
Decided December 3, 2013No. 12-562PublishedCited by 274 opinions
1Opinion of the CourtJustice Scalia
*33 We decide whether the penalty for tax underpayments attributable to valuation misstatements, 26 U.S.C. § 6662 (b)(3), is applicable to an underpayment resulting from a basis-inflating transaction subsequently disregarded for lack of economic substance.
I. The Facts
A
This case involves an offsetting-option tax shelter, variants of which were marketed to high-income taxpayers in the late 1990's. Tax shelters of this type sought to generate large paper losses that a taxpayer could use to reduce taxable income. They did so by attempting to give the taxpayer an artificially high basis in a…
2Cases cited16 opinions
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Reiter v. Sonotone Corp.Supreme Court of the United States · 1979
- Mohamad v. Palestinian AuthoritySupreme Court of the United States · 2012
- Bruesewitz v. Wyeth LLCSupreme Court of the United States · 2011
- Maracich v. SpearsSupreme Court of the United States · 2013
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3Cited by274 opinions
- Jennings v. RodriguezSupreme Court of the United States · 2018
- Kisor v. WilkieSupreme Court of the United States · 2019
- Encino Motorcars, LLC v. NavarroSupreme Court of the United States · 2018
- Loughrin v. United StatesSupreme Court of the United States · 2014
- Bunn v. Fed. Deposit Ins. Corp.Court of Appeals for the Seventh Circuit · 2018
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