U.S. v. Woods
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|Case Term||OT 2013|
|Question Presented||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.|
|Lower Court's Decision||Not Addressed|
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Outcome - Reverse
This case was decided on 02 December, 2013.