Tax attorney, Ajay Gupta, recently wrote an article about United States v. Woods, a case scheduled onOctober 9, to be heard by the Supreme Court. The heart of the case is about apenalty for a tax deficiency. The tax deficiency was attributable to a mistake in valuation when thetransaction was disregarded for having no economic substance. Gupta’s position is thatthe government is overreaching in its analysis of the words “relate to.”
See Sarah Choi, Discussion of United States v. Woods, Wealth Strategies, Oct. 7, 2013.
Special thanks to Jim Hillhouse (Professional Legal Marketing (PLM, Inc.)) for bringing this article to my attention.
