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.
Petition 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 2013
The time to file the joint appendix and petitioner's brief on the merits is extended to and including May 30, 2013.
Apr 4 2013
The time to file respondents' brief on the merits is extended to and including July 22, 2013.
On Monday the Court granted five new cases and issued four opinions in argued cases. The archived Live Blog is here.
On Thursday the Justices will meet for their May 23 Conference. Our list of “Petitions to watch” for that Conference is here.
Bloomberg Law and SCOTUSblog’s Supreme Court Challenge
Current Standings - Top 5 Teams
1. The Silent Ts
Georgetown University Law Center
1. Ninos Angels
George Washington University Law School
1. Protect Sam Chase
St. Johns University School of Law
1. Bro Bono
Indiana University -Bloomington, Maurer School of Law
5. Motion to Strike
Cornell University Law School
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