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← 131 TC 197 - Hoyle v. Comm'r

Hoyle v. Comm'r’s Empirical Analysis

2008

Citation profile

193
cited by 193 later decisions
July 2020
most recently cited

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 ·

1790200820102020decided

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.

  1. “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
  2. “[W]here a taxpayer alleges no notice of deficiency was mailed he has * * * '[identified] an irregularity[.]'”
    7 later decisions quote this exact passage
  3. “[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 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.