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← 114 TC 492 - Offiler v. Commissioner

Offiler v. Commissioner’s Empirical Analysis

2000

Citation profile

134
cited by 134 later decisions
June 2019
most recently cited

2 federal appellate ·

Relationships

Relies on Goza v. Commissioner · Monge v. Commissioner · Moore v. Commissioner · Savage 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 134 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “if the person did not receive any statutory notice of deficiency for such tax liability”
    4 later decisions quote this exact passage
  2. “within 30 days from the date of this letter.”
    4 later decisions quote this exact passage
  3. “[n]o levy may be made on any property or right to property of any person unless the Secretary has notified such person in writing of their right to a hearing under this section before such levy is made.”
    2 later decisions 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.