The Missed Jurisdictional Argument in 'U.S. v. Woods'

Bloomberg BNA Tax Insights, December 2013

U Iowa Legal Studies Research Paper No. 14-02

5 Pages Posted: 19 Dec 2013 Last revised: 28 Jan 2014

Andy Grewal

University of Iowa - College of Law

Abstract

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

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

Amandeep S. Grewal (Contact Author)

University of Iowa - College of Law ( email )

Melrose and Byington
Iowa City, IA 52242
United States

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