U.S. v. WOODS

No. 12-562.

134 S.Ct. 557 (2013)

187 L.Ed.2d 472

UNITED STATES, Petitioner v. Gary WOODS.

Supreme Court of United States.

Decided December 3, 2013.


Attorney(s) appearing for the Case

Malcolm L. Stewart , Washington, DC, for Petitioner.

Gregory G. Garre , Washington, DC, for Respondent.

Joel N. Crouch , Meadows, Collier, Reed, Cousins, Crouch & Ungerman LLP, Dallas, TX, Gregory G. Garre , Counsel of Record, Brian D. Schmalzbach , Katya S. Cronin , Latham & Watkins LLP, Washington, DC, for Respondent.

Donald B. Verrilli, Jr. , Solicitor General, Kathryn Keneally , Assistant Attorney General, Malcolm L. Stewart , Deputy Solicitor General, John F. Bash , Assistant to the Solicitor General, Gilbert S. Rothenberg , Richard Farber, Arthur T. Catterall , Attorneys, Department of Justice, Washington, DC, for Petitioner.


Justice SCALIA delivered the opinion of the Court.

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...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases