United States v. Nevada Partners Fund, LLC

Pending petition
Docket No. Op. Below Argument Opinion Vote Author Term
13-343 5th Cir TBD TBD TBD TBD TBD

Issue: Whether the overstatement penalty in Section 6662 of the Internal Revenue Code applies to an underpayment of tax 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 adjusted basis of property.

DateProceedings and Orders
Sep 17 2013Petition for a writ of certiorari filed. (Response due October 17, 2013)
Oct 15 2013Order extending time to file response to petition to and including November 18, 2013.
Nov 18 2013Brief of respondents Nevada Partners Fund, LLC, By and Through Sapphire II, Inc., Tax Matters Partner, et al. in opposition filed.
Nov 26 2013Reply of petitioner United States filed.
Dec 4 2013DISTRIBUTED for Conference of January 10, 2014.
Jan 13 2014Petition GRANTED. Judgment VACATED and case REMANDED for further consideration in light of United States v. Woods, 571 U. S. ___ (2013).
Feb 14 2014JUDGMENT ISSUED.
 
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