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← 205 F.3d 54 - Laurence M. Addington, David M. Cohn, John Sann and Marianne Sann v. Commissioner of Internal Revenue

Laurence M. Addington, David M. Cohn, John Sann and Marianne Sann v. Commissioner of Internal Revenue’s Empirical Analysis

2000

Citation profile

33
cited by 33 later decisions
May 2016
most recently cited

1 federal appellate ·

Relationships

Relies on United States v. Boyle · Freytag v. Commissioner · Freytag v. Commissioner · Heasley v. Commissioner · Goldman 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “It is unreasonable for taxpayers to rely on the advice of someone who they should know has a conflict of interest.”
    7 later decisions quote this exact passage · from the majority
  2. “In general, it is unreasonable to rely on an adviser who lacks knowledge about the industry in which the taxpayer is investing.”
    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.