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.

United States v. Woods

Docket No. Op. Below Argument Opinion Vote Author Term
12-562 5th Cir. TBD TBD TBD TBD OT 2013
 

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.

SCOTUSblog Coverage

DateProceedings and Orders
Nov 6 2012Petition for a writ of certiorari filed. (Response due December 6, 2012)
Dec 19 2012DISTRIBUTED for Conference of January 11, 2013.
Jan 4 2013Response Requested . (Due February 4, 2013)
Feb 4 2013Brief of respondents Gary Woods, as Tax Matters Partner of Tesoro Drive Partners, et al. in opposition filed.
Feb 20 2013DISTRIBUTED for Conference of March 15, 2013.
Feb 20 2013Reply of petitioner United States filed. (Distributed)
Mar 18 2013DISTRIBUTED for Conference of March 22, 2013.
Mar 25 2013Petition GRANTED. In addition to the question presented by the petition, the parties are directed to brief and argue the following question: Whether the district court had jurisdiction in this case under 26 U. S. C. §6226 to consider the substantial valuation misstatement penalty.
Apr 4 2013The time to file the joint appendix and petitioner's brief on the merits is extended to and including May 30, 2013.
Apr 4 2013The time to file respondents' brief on the merits is extended to and including July 22, 2013.