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← 129 TC 178 - Baltic v. Comm'r

Baltic v. Comm'r’s Empirical Analysis

2007

Citation profile

20
cited by 20 later decisions
December 2017
most recently cited

Relationships

Relies on Slodov v. United States · Florida Peach Corp. v. Commissioner · Moore v. Commissioner · Kindred v. Commissioner · Steele v. United States

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

  1. “Cashing a check does not mean that the IRS has accepted the offer.”
    2 later decisions quote this exact passage
  2. “a challenge to the amount of the tax liability made in the form of an OIC-DATL by a taxpayer who has received a notice of deficiency is a challenge to the underlying tax liability.”
    1 later decision quote this exact passage
  3. “the thinnest of supports for any general proposition that an OIC-DATL is not a challenge to an 'underlying tax liability'”
    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.