Petition of the day
The petition of the day is:
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; and (2) whether the district court had jurisdiction in this case under 26 U.S.C. § 6226 to consider the substantial valuation misstatement penalty.
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/