Supreme Court Poised to Consider Penalty Issue in Woods
The government has asked the Supreme Court to resolve a longstanding conflict in the circuits on the applicability of the penalty for valuation misstatements in United States v. Woods, No. 12-562. The...
View ArticleSupreme Court Denies Certiorari in Union Carbide
The Court this morning denied Union Carbide’s petition for certiorari that sought review of the Second Circuit’s denial of claimed research and experimentation credits for the costs of certain supplies...
View ArticleSupreme Court Agrees to Hear Penalty Issue in Woods
The Court this morning granted the government’s petition for certiorari in United States v. Woods, No. 12-562. As we recently reported, the issue presented in the petition concerns the applicability...
View ArticleGovernment Brief in Woods Due on May 30
We previously reported on the Court’s grant of certiorari in Woods, noting that the government’s opening brief would be due on May 9. If you are looking for the brief, be advised that the Court has...
View ArticleSupreme Court Briefing Underway in Woods on Penalty and TEFRA Issues
The government has filed its opening brief in the Supreme Court in the Woods case, which involves whether the 40% gross valuation overstatement penalty applies in the context of a basis-inflating...
View ArticleTaxpayers’ Brief Filed in Woods
The taxpayers have filed their response brief in the Supreme Court in the Woods case, contending first that the courts lacked jurisdiction to impose the penalties requested by the IRS and, second,...
View ArticleBriefing Complete in Woods
The government has filed its reply brief in the Supreme Court in Woods. See our reports on the opening briefs here and here. The discussion of the jurisdictional issue focuses less on the textual...
View ArticleSupreme Court Struggles to Unravel TEFRA Jurisdiction in Woods Oral Argument
The Supreme Court held oral argument in United States v. Woods on October 9. As we have previously reported, the case presents two distinct questions: (1) a TEFRA jurisdictional question concerning...
View ArticleSupreme Court Rules for Government on Both Issues in Woods
The Supreme Court this morning ruled 9-0 in favor of the government on both issues in Woods, holding that: (1) there is partnership-level TEFRA jurisdiction to consider the appropriateness of a...
View ArticleSupreme Court Poised to Consider Penalty Issue in Woods
The government has asked the Supreme Court to resolve a longstanding conflict in the circuits on the applicability of the penalty for valuation misstatements in United States v. Woods, No. 12-562. The...
View ArticleSupreme Court Denies Certiorari in Union Carbide
The Court this morning denied Union Carbide’s petition for certiorari that sought review of the Second Circuit’s denial of claimed research and experimentation credits for the costs of certain supplies...
View ArticleSupreme Court Agrees to Hear Penalty Issue in Woods
The Court this morning granted the government’s petition for certiorari in United States v. Woods, No. 12-562. As we recently reported, the issue presented in the petition concerns the applicability...
View ArticleGovernment Brief in Woods Due on May 30
We previously reported on the Court’s grant of certiorari in Woods, noting that the government’s opening brief would be due on May 9. If you are looking for the brief, be advised that the Court has...
View ArticleSupreme Court Briefing Underway in Woods on Penalty and TEFRA Issues
The government has filed its opening brief in the Supreme Court in the Woods case, which involves whether the 40% gross valuation overstatement penalty applies in the context of a basis-inflating...
View ArticleTaxpayers’ Brief Filed in Woods
The taxpayers have filed their response brief in the Supreme Court in the Woods case, contending first that the courts lacked jurisdiction to impose the penalties requested by the IRS and, second,...
View ArticleBriefing Complete in Woods
The government has filed its reply brief in the Supreme Court in Woods. See our reports on the opening briefs here and here. The discussion of the jurisdictional issue focuses less on the textual...
View ArticleSupreme Court Struggles to Unravel TEFRA Jurisdiction in Woods Oral Argument
The Supreme Court held oral argument in United States v. Woods on October 9. As we have previously reported, the case presents two distinct questions: (1) a TEFRA jurisdictional question concerning...
View ArticleSupreme Court Rules for Government on Both Issues in Woods
The Supreme Court this morning ruled 9-0 in favor of the government on both issues in Woods, holding that: (1) there is partnership-level TEFRA jurisdiction to consider the appropriateness of a...
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