Editor's Note :

On Tuesday, May 28, at 9:30 a.m. we expect orders from the May 23 Conference. We expect opinions in argued cases at 10 a.m. We will begin live blogging shortly before 9:30.

Mary Dwyer Petitions

Posted Fri, March 1st, 2013 11:31 pm

Petition of the day

The petition of the day is:

United States v. Woods
12-562

Issue: (1) Whether Section 6662 of the Internal Revenue Code, which prescribes a penalty for an underpayment of federal income tax that is “attributable to” an overstatement of basis in property, 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. (2) Whether the district court had jurisdiction in this case under 26 U.S.C. §6226 to consider the substantial valuation misstatement penalty.

Posted in U.S. v. Woods, Cases in the Pipeline

Recommended Citation: Mary Pat Dwyer, Petition of the day, SCOTUSblog (Mar. 1, 2013, 11:31 PM), http://www.scotusblog.com/2013/03/petition-of-the-day-410/