United States v. Woods (571 U.S. 31)
U.S. Supreme Court · decided December 3, 2013 · Supreme Court Database (Spaeth)
- Citation
- 571 U.S. 31 · 134 S. Ct. 557
- Docket
- No. 12-562
- Argued
- October 9, 2013
- Decided
- December 3, 2013
- Term
- October Term 2013
- Vote
- 9–0
- Majority author
- Justice Scalia
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
How the Justices voted
- Majority
- Chief Justice Roberts, Justice Scalia (wrote), Justice Kennedy, Justice Thomas, Justice Ginsburg, Justice Breyer, Justice Alito, Justice Sotomayor, Justice Kagan
Oral argument transcript and advocates · Opinion on Justia
Opinion excerpt
(Slip Opinion) OCTOBER TERM, 2013 1 Syllabus NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued. The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader. See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337. SUPREME COURT OF THE UNITED STATES Syllabus UNITED STATES v. WOODS CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT No. 12–562. Argued October 9, 2013—Decided December 3, 2013 Respondent Gary Woods and his employer, Billy Joe McCombs, partici- pated in an offsetting-option tax shelter designed to generate large paper losses that they could use to reduce their taxable income. To that end, they purchased from Deutsche Bank a series of currency- option spreads. Each spread was a package consisting of a long op- tion, which Woods and McCombs purchased from Deutsche Bank and for which they paid a premium, and a short option, which Woods and McCombs sold to Deutsche Bank and for which they received a pre- mium. Because the premium paid for the long option was largely off- set by the premium received for the short option, the net cost of the package to Woods and McCombs was substantially less than the cost of the long option alone. Woods and McCombs…
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