Meyer v. Comm'r’s Empirical Analysis

Citation profile

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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Section 6330(d) imposes certain procedural prerequisites on judicial review of collection matters. Much like the Court’s deficiency jurisdiction, the Court’s jurisdiction under section 6330(d) is dependent upon a valid determination letter and a timely filed petition for review. See Rule 330(b). Like a notice of deficiency under section 6213(a), an Appeals Office determination letter is a taxpayer’s “ticket” to the Tax Court. See Offiler v. Commissioner, 114 T.C. 492, 498 (2000); see also Mulvania v. Commissioner, 81 T.C. 65, 67 (1983); Gati v. Commissioner, 113 T.C. 132, 134 (1999). Moreover, a petition for review under section 6330 must be filed with the appropriate court within 30 days of the mailing of the determination letter. See McCune v. Commissioner, 115 T.C. 114 (2000).”

   1 later decision quote this exact passage
   e.g. Lunsford v. Comm'r