United States v. Woods, 571 U.S. 31 (2013), was a United States Supreme Court case in which the Court addressed whether district courts have jurisdiction regarding provisions of the Internal Revenue Service Code and its implementation.[1] The court held unanimously that a district court has jurisdiction in the application of the Internal Revenues Service Code to a partnership-level proceeding when it is applied to that partnership. The court additionally found that a transaction determined to lack economic substance can still trigger the penalty for overstatement because the overstatement and the action that led to it are inherently tied together.[2]
| United States v. Woods | |
|---|---|
 | |
| Argued October 9, 2013 Decided December 3, 2013 | |
| Full case name | United States, Petitioner v. Gary Woods |
| Docket no. | 12-562 |
| Citations | 571 U.S. 31 (more) 134 S. Ct. 557; 187 L. Ed. 2d 472; 2013 U.S. LEXIS 8776; 82 U.S.L.W. 4015 |
| Argument | Oral argument |
| Opinion announcement | Opinion announcement |
| Case history | |
| Prior | Petitioners request granted, US Dis. Ct.; District Court affirmed by 5th Cir. Ct. |
| Holding | |
| The district court had jurisdiction to determine whether the partnerships' lack of economic substance could justify imposing a valuation-misstatement penalty on the partners. | |
| Court membership | |
| |
| Case opinion | |
| Majority | Scalia, joined by unanimous |
| Laws applied | |
| Tax Equity and Fiscal Responsibility Act of 1982 | |
References edit
External links edit
- Text of United States v. Woods, 571 U.S. 31 (2013) is available from: CourtListener Google Scholar Justia Oyez (oral argument audio) Supreme Court (slip opinion) (archived)
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