The Missed Jurisdictional Argument in 'U.S. v. Woods'
University of Iowa - College of Law
Bloomberg BNA Tax Insights, December 2013
U Iowa Legal Studies Research Paper No. 14-02
In U.S. v Woods, the Supreme Court settled an important jurisdictional question related to tax penalties -- or so it seemed. Although the Court held that the district court enjoyed jurisdiction, the taxpayer missed an argument that could have led to the opposite conclusion. And given the wide latitude that parties enjoy in bringing jurisdictional challenges, the lower courts may find themselves reconsidering the issue purportedly resolved by the Court in Woods. This short Article explains.
Number of Pages in PDF File: 5Accepted Paper Series
Date posted: December 19, 2013 ; Last revised: January 28, 2014
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