Marretta v. Commissioner IRS’s Empirical Analysis
2006
Citation profile
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.
“[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 majoritye.g. Philpott v. Comm'r
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.