Bloomberg BNA Tax Insights, December 2013
5 Pages Posted: 19 Dec 2013 Last revised: 28 Jan 2014
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.
Suggested Citation: Suggested Citation
Grewal, Andy, The Missed Jurisdictional Argument in 'U.S. v. Woods'. Bloomberg BNA Tax Insights, December 2013 ; U Iowa Legal Studies Research Paper No. 14-02. Available at SSRN: https://ssrn.com/abstract=2369512