Gray v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate ·

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

1. “a petition filed by a pro se litigant should be liberally construed.”

   2 later decisions quote this exact passage
   e.g. 2012 T.C. Memo. 245 - Abarca v. Comm'r · 2017 T.C. Memo. 13 - Phillips v. Comm'r

2. “The statutory scheme of section 6330 clearly contemplates that the underlying tax liability may be challenged in designated circumstances in a section 6330 proceeding and requires the determination to consider such a challenge when properly made. See sec. 6330(c)(2)(B), (3)(B). However, the statute does not distinguish between determinations where the underlying tax liability is properly at issue and those where it is not. The same 30-day period to appeal the determination applies across the board. See sec. 6330(d).”

   1 later decision quote this exact passage
   e.g. Gray v. Commissioner

3. “Because * * * [the taxpayer] requested an abatement of interest in connection with her section 6330 hearing, the notice of determination included a determination not to abate interest under section 6404(e), and the petition seeks our review of that determination, we conclude that the notice and petition confer jurisdiction under section 6404(h) that is independent of section 6330.”

   1 later decision quote this exact passage
   e.g. Brian H. McLane v. Commissioner