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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

Docket No.13-343
Op. Below5th Cir

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.

Proceedings & orders timeline

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

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