United States v. Woods

United States v. Woods, 571 U.S. ___ (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
Supreme Court of the United States
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. ___ (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
Chief Justice John Roberts Associate Justices Antonin Scalia · Anthony Kennedy Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan
Case opinion
Majority	Scalia, joined by unanimous
Laws applied
Tax Equity and Fiscal Responsibility Act of 1982

References

1. "United States v. Woods - LII Supreme Court Bulletin - LII / Legal Information Institute". Retrieved August 2, 2014.
2. United States v. Woods, No. 12-562, 571 U.S. ___, 134 S. Ct. 557 (2013).

External links

• Text of United States v. Woods, 571 U.S. ___ (2013) is available from:  CourtListener  Google Scholar  Justia  Oyez (oral argument audio)  Supreme Court (slip opinion)