United States v. Woods, 571 U.S. 31 (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.
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