Kendricks v. Comm'r’s Empirical Analysis
2005
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 107 later decisions — most recently May 2020 · most notably Kindred v. Commissioner (2006), McLaine v. Commissioner (2012)
2 federal appellate ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 11 U.S.C. § 505
Relies on Welch v. Helvering · Cooter & Gell v. Hartmarx Corp. · Goza v. Commissioner · Raleigh v. Illinois Department of Revenue · Florida Peach Corp. v. Commissioner
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 107 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“there was no offer in compromise before Appeals, there was no abuse of discretion in Appeals' failing to consider an offer in compromise”
5 later decisions quote this exact passage“the amount or legality of any tax, any fine or penalty relating to a tax, or any addition to tax, whether or not previously assessed, whether or not paid, and whether or not contested before and adjudicated by a judicial or administrative tribunal of competent jurisdiction.”
1 later decision quote this exact passagee.g. Sabath v. Comm'r“[W]hen the * * * [bankruptcy] provides the taxpayer the opportunity to object to the IRS's proof of claim for an unpaid Federal tax liability, the taxpayer is afforded an opportunity to dispute the liability, as contemplated by Congress in section 6330(c)(2)(B).”
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.