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← 105 TC 324 - Cluck v. Commissioner

Cluck v. Commissioner’s Empirical Analysis

1995

Citation profile

91
cited by 91 later decisions
1
states following
April 2020
most recently cited

1 state decisions

How this case has been cited

Cited by 91 later decisions — most recently April 2020 · most notably Estate of Letts v. Commissioner (1997), Lofstrom v. Comm'r (2005)

1 state decisions

3601995200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on New Colonial Ice Co. v. Helvering · Neely v. Commissioner · Bixby v. Commissioner · Tokarski v. Commissioner · United States v. Ludey

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 91 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “is based on the theory that the taxpayer owes the Commissioner the duty to be consistent in the tax treatment of items and will not be permitted to benefit from the taxpayer's own prior error or omission.”
    3 later decisions quote this exact passage
  2. “the Commissioner may recompute a taxpayer's taxable income or loss for a year in which the statute of limitations would otherwise bar assessment in order to redetermine the amount of the NOL deduction claimed in an open year”
    1 later decision quote this exact passage
  3. “lack of due care or failure to do what a reasonable and ordinarily prudent person would do under the circumstances”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.