155 Cal. App. 4th 704 - Sahadi v. Scheaffer’s Empirical Analysis

Citation profile

2 federal appellate · 21 state decisions

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

1. “It created a special bright-line rule for accounting malpractice for the negligent preparation of tax returns that are subsequently audited by taxing authorities. The court held that the date in which the IRS makes a final determination of a tax deficiency serves by operation of law as the date of accrual of the statute of limitations in such cases, noting: `The deficiency assessment serves as a finalization of the audit process and the commencement of actual injury because it is the trigger that allows the IRS to collect amounts due and the point at which the accountant's alleged negligence has caused harm to the taxpayer.'”

   1 later decision quote this exact passage
   e.g. 402 Ill. App. 3d 23 - Federated Industries, Inc. v. Reisin

2. “The use of the date of deficiency assessment to mark the date of actual injury in accountant malpractice cases provides the parties with a bright line that ... provides certainty in terms of the statute's application.... [U]niformity in application serves a more important function when interpreting statutes of limitation than does the identification of the precise point at which some harm might be said to have occurred, even if negative collateral consequences might arise from the tentative assessment of additional tax liability.”

   1 later decision quote this exact passage
   e.g. Moss v. Duncan

3. “Although [the defendants'] alleged negligence may have been `discovered' during the audit, such potential liability could not amount to actual harm until the date of the deficiency tax assessment or finality of the audit process.”

   1 later decision quote this exact passage
   e.g. 402 Ill. App. 3d 23 - Federated Industries, Inc. v. Reisin