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U.S. v. WOODS

No. 12-562.

134 S.Ct. 557 (2013)

187 L.Ed.2d 472

UNITED STATES, Petitioner v. Gary WOODS.

Supreme Court of United States.

Decided December 3, 2013.

Attorney(s) appearing for the Case

Malcolm L. Stewart, Washington, DC, for Petitioner.

Gregory G. Garre, Washington, DC, for Respondent.

Joel N. Crouch, Meadows, Collier, Reed, Cousins, Crouch & Ungerman LLP, Dallas, TX, Gregory G. Garre, Counsel of Record, Brian D. Schmalzbach, Katya S. Cronin, Latham & Watkins LLP, Washington, DC, for Respondent.

Donald B. Verrilli, Jr., Solicitor General, Kathryn Keneally, Assistant Attorney General, Malcolm L. Stewart, Deputy Solicitor General, John F. Bash, Assistant to the Solicitor General, Gilbert S. Rothenberg, Richard Farber, Arthur T. Catterall, Attorneys, Department of Justice, Washington, DC, for Petitioner.

Justice SCALIA delivered the opinion of the Court.

We decide whether the penalty for tax underpayments attributable to valuation misstatements, 26 U.S.C. § 6662(b)(3), is applicable to an underpayment resulting from a basis-inflating transaction subsequently disregarded for lack of economic substance.

I. The Facts

A

This case involves an offsetting-option tax shelter, variants of which were marketed to high-income taxpayers in the...

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