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← 168 FAPPX 528 - Marretta v. Commissioner IRS

Marretta v. Commissioner IRS’s Empirical Analysis

2006

Citation profile

9
cited by 9 later decisions
June 2016
most recently cited

Relationships

Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6663 · 26 U.S.C. § 7454 · 26 U.S.C. § 7482

Relies on Spies v. United States · Commissioner of Internal Revenue v. Glenshaw Glass Company · Solomon v. Commissioner · Rickel v. Commissioner · Estate of Josephine Mazzoni, Deceased, Peter Mazzoni, and Peter Mazzoni v. Commissioner of Internal Revenue. Appeal of Peter Mazzoni, Individually and as of the Estate of Josephine Mazzoni, in No. 19338. Charles J. Runzo and Lena Runzo, in No. 19339 v. Commissioner of Internal Revenue

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

  1. “[i]f the Secretary establishes that any portion of an underpayment is attributable to fraud, the entire underpayment shall be treated as attributable to fraud, except with respect to any portion of the underpayment which the taxpayer establishes (by a preponderance of the evidence) is not attributable to fraud.”
    1 later decision quote this exact passage · from the majority

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.