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← 142 TC 269 - Sotiropoulos v. Commissioner

Sotiropoulos v. Commissioner’s Empirical Analysis

2014

Citation profile

2
cited by 2 later decisions
December 2017
most recently cited

Relationships

Relies on Taylor v. Voss · Estate of Young v. Commissioner · William Prentice Cooper, III v. Commissioner · Tigers Eye Trading, LLC v. Comm'r · Lewy 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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “to decide whether the statutory provision alleged to divest us of jurisdiction applies, i.e., whether the U.K. taxes paid by petitioner have been 'refunded in whole or in part' within the meaning of section 905(c)(1)(C ).”
    1 later decision quote this exact passage
  2. “[t]he amount of tax (if any) due * * * shall be paid by the taxpayer on notice and demand by the Secretary, and the amount of tax overpaid (if any) shall be credited or refunded to the taxpayer.”
    1 later decision quote this exact passage
  3. “Subchapter B of chapter 63 of the Code (relating to deficiency procedures) shall not apply with respect to the assessment of the amount due upon such redetermination.”
    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.