Booker Hobbs Jr v. United States of America Ex Rel Sandra Russell in Her Own Right and Internal Revenue Service’s Empirical Analysis

Citation profile

2 federal appellate · 1 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The term “tax administration”— (A) means— (i) the administration, management, conduct, direction, and supervision of the execution and application of the internal revenue laws or related statutes (or equivalent laws and statutes of a State) and tax conventions to which the United States is a party, and (ii) the development and formulation of Federal tax policy relating to existing or proposed internal revenue laws, related statutes, and tax conventions, and (B) includes assessment, collection, enforcement, litigation, publication, and statistical gathering functions under such laws, statutes, or conventions.”

   1 later decision quote this exact passage · from the majority
   e.g. In Re Guidry

2. “own compliance with the federal tax laws was something of key concern to the IRS; his position required him to examine the accuracy of corporate and individual tax returns and, in turn, to have a sophisticated understanding of the tax laws,”

   1 later decision quote this exact passage · from the majority
   e.g. Gardner v. United States

3. “the 'management' and 'supervision' of a state's internal revenue laws [to] include[ ] ensuring that its employees are free from conflicts of interest that could undermine the integrity of its system of administering the state tax laws.”

   1 later decision quote this exact passage · from the majority
   e.g. Gardner v. United States