Grigoraci 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. “only if the taxpayer is the 'prevailing party', did not unreasonably protract the administrative or judicial proceedings, and exhausted available administrative remedies.”

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

2. “[i]n these circumstances, we are unpersuaded that petitioners are entitled to shift to respondent a portion of what appears to be [accounting firm's] fixed overhead.”

   1 later decision quote this exact passage · from the majority
   e.g. In Re Seay

3. “reasonable administrative costs incurred in connection with such administrative proceeding”

   1 later decision quote this exact passage · from the majority
   e.g. 2014 T.C. Memo. 75 - Carpentier v. Comm'r