Hoyle v. Comm'r’s Empirical Analysis
2008
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 193 later decisions — most recently July 2020 · most notably Thompson v. Commissioner (2013), Mason v. Comm'r (2009)
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
Relies on Goza v. Commissioner · Sego v. Commissioner · Giamelli v. Comm'r · United States v. Zolla · Frieling 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 193 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“underlying documents in addition to the tax transcripts, such as the taxpayer's return, a copy of the notice of deficiency, and the certified mailing list”
13 later decisions quote this exact passage“[W]here a taxpayer alleges no notice of deficiency was mailed he has * * * '[identified] an irregularity[.]'”
7 later decisions quote this exact passage“[W]here a taxpayer alleges no notice of deficiency was mailed he has * * * '[identified] an irregularity', thereby requiring the Appeals officer to do more than consult the computerized records”
3 later decisions quote this exact passagee.g. Silva v. Comm'r · Jordan v. Comm'r
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.