United States v. Woods
| Docket No. | Op. Below | Argument | Opinion | Vote | Author | Term |
|---|---|---|---|---|---|---|
| 12-562 | 5th Cir. | Oct 9, 2013 | Dec 3, 2013 | 9-0 | Scalia | OT 2013 |
Holding: The district court had jurisdiction to determine whether the partnerships’ lack of economic substance could justify imposing a valuation-misstatement penalty on the partners.
Judgment: Reversed and remanded, 9-0, in an opinion by Justice Scalia on December 3, 2013.
SCOTUSblog Coverage
- Opinion analysis: Tough day for the Fifth Circuit (Ronald Mann, December 4, 2013)
- Argument analysis: Justices focused on jurisdictional problem in tax penalties dispute (Ronald Mann, October 10, 2013)
- Argument preview: Court to resolve circuit split about tax penalties (Ronald Mann, October 2, 2013)
- Petition of the day (Mary Pat Dwyer, March 1, 2013)
| Date | Proceedings and Orders |
|---|---|
| Nov 6 2012 | Petition for a writ of certiorari filed. (Response due December 6, 2012) |
| Dec 19 2012 | DISTRIBUTED for Conference of January 11, 2013. |
| Jan 4 2013 | Response Requested . (Due February 4, 2013) |
| Feb 4 2013 | Brief of respondents Gary Woods, as Tax Matters Partner of Tesoro Drive Partners, et al. in opposition filed. |
| Feb 20 2013 | DISTRIBUTED for Conference of March 15, 2013. |
| Feb 20 2013 | Reply of petitioner United States filed. (Distributed) |
| Mar 18 2013 | DISTRIBUTED for Conference of March 22, 2013. |
| Mar 25 2013 | Petition GRANTED. In addition to the question presented by the petition, the parties are directed to brief and argue the following question: Whether the district court had jurisdiction in this case under 26 U. S. C. §6226 to consider the substantial valuation misstatement penalty. |
| Apr 4 2013 | The time to file the joint appendix and petitioner's brief on the merits is extended to and including May 30, 2013. |
| Apr 4 2013 | The time to file respondents' brief on the merits is extended to and including July 22, 2013. |
| May 30 2013 | Joint appendix filed. (Statement of costs filed.) |
| May 30 2013 | Brief of petitioner United States filed. |
| Jun 5 2013 | Brief amicus curiae of Professor Amandeep S. Grewal in support of neither party filed. |
| Jul 19 2013 | Brief of respondents Gary Woods, as Tax Matters Partner of Tesoro Drive Partners, et al. filed. (Distributed) |
| Jul 22 2013 | CIRCULATED. |
| Jul 23 2013 | SET FOR ARGUMENT on Wednesday, October 9, 2013. |
| Jul 25 2013 | Brief amicus curiae of Professor David J. Shakow filed. (Distributed) |
| Jul 26 2013 | Brief amici curiae of Gordon W. Bush, et al. filed. (Distributed) |
| Jul 26 2013 | Brief amici curiae of New Millennium Trading, LLC, et al. filed. (Distributed) |
| Jul 26 2013 | Brief amici curiae of Scott and Audrey Blum filed. (Distributed) |
| Jul 26 2013 | Brief amicus curiae of Partners in Jade Trading, LLC, et al. filed. VIDED. (Distributed) |
| Aug 2 2013 | Record received from U.S.C.A. for 5th Circuit is electronic and located on PACER. |
| Aug 2 2013 | Record received from U.S.D.C. for Western District of Texas is electronic. |
| Aug 19 2013 | Reply of petitioner United States filed. (Distributed) |
| Oct 8 2013 | Letter and attachments dated October 7, 2013 received from counsel for respondents. (Distributed) |
| Oct 9 2013 | Argued. For petitioner: Malcolm L. Stewart, Deputy Solicitor General, Department of Justice, Washington, D. C. For respondents: Gregory G. Garre, Washington, D. C. |
| Oct 28 2013 | Exhibits received from the U.S.D.C. for the Western District of Texas San Antonio Division. (Three boxes) |
| Dec 3 2013 | Judgment REVERSED Scalia, J., delivered the opinion for a unanimous Court. |
| Jan 6 2014 | JUDGMENT ISSUED. |
| Jan 15 2014 | Record from U.S.D.C. Western District of Texas (San Antonio) has been returned. |
