United States v. Nevada Partners Fund, LLC
Petition granted, judgment vacated and case remanded for further consideration in light of United States v. Woods on January 13, 2014
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.