Smith v. Comm'r’s Empirical Analysis
2009
Citation profile
13
cited by 13 later decisions
December 2019
most recently cited
4 federal appellate ·
Relationships
Applies 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Naftel v. Commissioner · Pyo v. Commissioner · Kluger v. Commissioner · Callahan v. Comm'r · Shaw 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the IRS often did not learn of the existence of tax shelters until after it conducted audits.”
1 later decision quote this exact passage“[t]he section 6707A penalty is not within our deficiency jurisdiction,”
1 later decision quote this exact passage“may not be reviewed in any judicial proceeding.”
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.