Discussion of United States v. Woods
Ajay Gupta, a tax attorney, discusses United States v. Woods, a case that the Supreme Court will hear on October 9. The Court is resolving an issue surrounding "an accuracy-related penalty for a tax underpayment 'attributable to' a valuation misstatement when the underlying transaction is disregarded for lack of economic substance." Gupta argues that the government is overreaching in its analysis of "relate to."
See United States v. Woods: Taking TEFRA to the Woodshed, 2013 TNT 194-11, taxanalysts.com, October 7, 2013.
Posted by Sarah Choi, Associate Editor, Wealth Strategies Journal
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