Tax Attorney Comments on United States v. Woods

Tax attorney, Ajay Gupta, recently wrote an article about  United States v. Woods, a case scheduled on October 9, to be heard by the Supreme Court. The heart of the case is about a penalty for a tax deficiency. The tax deficiency was attributable to a mistake in valuation when the transaction was disregarded for having no economic substance. Gupta's position is that the 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.