Reser v. Commissioner’s Empirical Analysis
1997
Citation profile
27 federal appellate ·
How this case has been cited
Cited by 68 later decisions — most recently May 2019 · most notably 101 F. App'x 34 - Alt v. Commissioner (2004), Cheshire v. Commissioner (2000)
27 federal appellate ·
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 United States v. Boyle · Higgins v. Smith · Cruz v. Hauck · Parham v. Cortese · Golsen v. Commissioner
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 68 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“any failure to make a reasonable attempt to comply”
3 later decisions quote this exact passage · from the majority“if, under all the circumstances, such reliance was reasonable and the taxpayer acted in good faith,”
2 later decisions quote this exact passage · from the majority“First, the promissory notes payable to Frost Bank were executed by Don and DRPC together, indicating on their face that Frost Bank did not lend the money to Don alone. Second, Frost Bank always deposited the loan proceeds directly into DRPC's account. Third, Don, individually, did not make any repayments on the loan to Frost Bank, but DRPC made both principal and interest payments to Frost Bank. Finally, DRPC's corporate tax returns reflected the notes as payable to Frost Bank, not to Don, even though the returns listed other notes payable to Don.... 24 ... Neither DRPC's 1987 nor 1988 corporate return reflected the alleged indebtedness to Don. Furthermore, there is no evidence that (1) Don ever received or that DRPC ever paid any interest or principal on these notes or (2) DRPC made any 'loan' repayments to Don.”
1 later decision quote this exact passage · from the majority
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.