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. (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/