Sunoco, Inc. v. Comm'r’s Empirical Analysis

Citation profile

1 federal appellate ·

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

1. “[Sunoco’s] overpayment claims include over-payments consisting in part of interest [the IRS] computed on the interim underpayment balances reflected in [Sunoco’s] account, so-called underpayment interest. [Sunoco] contends that the amounts of underpayment interest ... computed are too high. [Sunoco’s] overpayment claims also include overpayments consisting in part of interest computed on the interim overpayment balances reflected in [Sunoco’s] account, so-called overpayment interest. [Sunoco] contends that the amounts of overpayment interest respondent computed are too low.”

   1 later decision quote this exact passage
   e.g. Sunoco Inc. v. Commissioner

2. “For example, assume that, pursuant to section 6402(a), the Commissioner credits an overpayment of $1,000 against a liability of the same taxpayer for a different taxable year, but fails to include interest of $20 computed under section 6611 that is allowable on the overpayment. Under these facts, the taxpayer would have used $1,020 to satisfy a liability of $1,000. In effect, the taxpayer would have overpaid the liability against which the overpayment is credited by $20.”

   1 later decision quote this exact passage · from the majority
   e.g. Sunoco Inc. v. Commissioner