October Term 2000 · Docket 00-157
Can a product liability loss offset income from a different year?
The dispute centers on whether a product liability loss counts as a net operating loss for tax purposes.
Verified source milestones
- — An official oral-argument transcript was verified.
- — An official oral-argument transcript was verified.
The arguments, in order
This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.
Argument 1 ·
What happened at the argument
Eric Fox argued the product liability loss is a subset of the net operating loss.
Fox cited the district court's finding on page 36A of Appendix B.
Fox noted legislative history shows concern about delayed product liability suits.
Fox explained products might generate income before liability claims arise years later.
Read the official transcript for this argument · Official argument details
Sources used for this argument breakdown
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 3, lines 5-15 — Transcript, file page 3, lines 5-15
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
- Official Supreme Court Transcript — file page 51, lines 41-58 — Transcript, file page 51, lines 41-58
A citizen's guide to the whole case
What this case is about
United Dominion Industries seeks to treat a product liability loss as a net operating loss. The United States opposes this classification. The case tests the scope of tax loss deductions.
Official sources for this section
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
How the case got here
The Supreme Court heard oral argument in this case on March 26, 2001.
Official sources for this section
- Official Supreme Court Transcript — file page 3, lines 5-15 — Transcript, file page 3, lines 5-15
- Official Supreme Court Transcript — file page 51, lines 41-58 — Transcript, file page 51, lines 41-58
What each side wants
United Dominion Industries wants the Court to allow the product liability loss to offset income from a different year.
The United States wants the Court to deny the offset and uphold the tax assessment.
Official sources for this section
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
What each side says
United Dominion Industries argues the loss is a subset of the net operating loss under the tax code.
The United States argues the loss cannot be claimed on a separate return by the involved corporations.
Official sources for this section
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
What the justices asked
Chief Justice Rehnquist asked if the case is submitted after the arguments concluded.
Official sources for this section
- Official Supreme Court Transcript — file page 51, lines 41-58 — Transcript, file page 51, lines 41-58
Why it matters
This case defines how businesses calculate taxable income. It determines whether delayed liability claims reduce current tax bills. The outcome shapes corporate tax planning strategies nationwide.
Official sources for this section
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
What happens next
This article currently covers the argument record. Use the official docket link for later case activity.
Official sources for this section
- Official Supreme Court Transcript — file page 3, lines 5-15 — Transcript, file page 3, lines 5-15
- Official Supreme Court Transcript — file page 51, lines 41-58 — Transcript, file page 51, lines 41-58
Official Court provenance
Official docket and case history · Official Supreme Court oral-argument detail page
Title and summary sources
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
- Official Supreme Court Transcript — file page 23, lines 3-37 — Transcript, file page 23, lines 3-37
- Official Supreme Court Transcript — file page 3, lines 17-3 — Transcript, file page 3, lines 17-3
- Official Supreme Court Transcript — file page 47, lines 1-9 — Transcript, file page 47, lines 1-9
- Official Supreme Court Transcript — file page 5, lines 5-47 — Transcript, file page 5, lines 5-47
- Official Supreme Court Transcript — file page 50, lines 11-39 — Transcript, file page 50, lines 11-39
Revision history
- Revision 1 · Official Transcript ·
Correction: Rewritten to the concise citizen-facing editorial standard.
- Revision 2 · Official Transcript ·
Correction: Migrated to the dated official Court activity contract without model use.