Colvin v. Commissioner’s Empirical Analysis
2005
Citation profile
Relationships
Applies 26 U.S.C. § 212 · 26 U.S.C. § 262
Relies on Little v. Liquid Air Corp. · Badaracco v. Commissioner · United States v. Gilmore · Hillsboro National Bank v. Commissioner · Nissho-Iwai American Corp. v. Kline
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“even if the Commissioner had a legal duty to accept the amended return, it would have no impact on the deficiencies upheld by the Tax Court, because they were issued before * * * [the taxpayer] attempted to submit his amended return, and amended returns do not vitiate deficiencies that have already been issued.”
2 later decisions quote this exact passage · from the majority“the Internal Revenue Code does not explicitly provide either for a taxpayer's filing, or for the Commissioner's acceptance of an amended return; instead, an amended return is a creature of administrative origin and grace.”
2 later decisions quote this exact passage · from the majority“the management, conservation, or maintenance of property held for the production of income.”
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.