US v. Woods


(United States Supreme Court) – The Fifth Circuit Court of Appeal’s affirmation of the district court’s holding that defendants’ partnerships were properly disregarded as shams but that the valuation-misstatement penalty did not apply, is reversed, where: 1) the district court had jurisdiction to determine whether the partnerships’ lack of economic substance could justify imposing a valuation-misstatement penalty on the partners; and 2) the penalty is applicable to tax underpayments resulting from the defendant-partners’ participation in the COBRA tax shelter.