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← 122 TCNO 7 - Joseph Dutton v. Commissioner

Joseph Dutton v. Commissioner’s Empirical Analysis

2004

Citation profile

2
cited by 2 later decisions
September 2004
most recently cited

Relationships

Relies on Russel William Burket v. Ronald Angelone, Director, Virginia Department of Corrections · Woods v. Commissioner · Hildebrand v. Commissioner · Krause v. Commissioner · Dorchester Indus. v. Comm'r

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

  1. “(1) Where a mistake of both parties at the time a contract was made as to a basic assumption on which the contract was made has a material effect on the agreed exchange of performances, the contract is voidable by the adversely affected party unless he bears the risk of the mistake under the rule stated in sec. 154. (2) In determining whether the mistake has a material effect on the agreed exchange of performances, account is taken of any relief by way of reformation, restitution, or otherwise. [Emphasis supplied.]”
    1 later decision quote this exact passage
  2. “Once the IRS accepts the offer in writing, I/we have no right to contest, in court or otherwise, the amount of the tax liability.”
    1 later decision quote this exact passage
  3. “of material fact sufficient to cause the offer agreement to be reformed or set aside”
    1 later decision 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.