United States v. Bell’s Empirical Analysis
2003
Citation profile
2 federal appellate · 1 district · 2 state decisions
Relationships
Applies 26 U.S.C. § 1 (Airport and Airway Extension Act of 2008) · 26 U.S.C. § 11 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6700 · 26 U.S.C. § 6701 · 26 U.S.C. § 7402 · 26 U.S.C. § 7408 · 26 U.S.C. § 861 (Foreign Investors Tax Act of 1966)
Relies on Central Hudson Gas Electric Corporation v. Public Service Commission of New York · Virginia State Board of Pharmacy v. Virginia Citizens Consumer Council, Inc. · Near v. State of Minnesota Olson · Bates v. State Bar of Arizona · Helvering v. Clifford
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“all income from whatever source derived.” 26 U.S.C. § 61 (a). Bell claims that the word”
2 later decisions quote this exact passage · from the majority“AND NOW, this 10th day of January, 2003, in accordance with the accompanying memorandum, it is hereby ORDERED that plaintiff's motion for preliminary injunction (Doc. 34) is GRANTED. It is further ORDERED that: 1. Thurston Bell and his representatives, agents, servants, employees, attorneys, and those persons in active concert or participation with him, are preliminarily enjoined from directly or indirectly, by means of false, deceptive, or misleading commercial speech: a. Organizing, promoting, marketing, or selling (or assisting therein) the tax shelter, plan, or arrangement known as "the U.S. Sources argument” (also known as “the section 86 T argument”) or any other abusive tax shelter, plan or arrangement that incites taxpayers to attempt to violate the internal revenue laws or unlawfully evade the assessment or collection of their federal tax liabilities or unlawfully claim improper tax refunds; b. Further engaging in any conduct subject to .penalty under 26 U.S.C. § 6700 , i.e. making or furnishing, in connection with the organization or sale of an abusive shelter, plan, or arrangement, a statement they know or have reason to know is false or fraudulent as to any material part; c. Further engaging in any conduct subject to penalty under 26 U.S.C. § 6701 , i.e. assisting others in the preparation of any tax forms or other documents to be used in connection with any material matter arising under the internal revenue laws and which they know will (if so used) result in the”
1 later decision quote this exact passage · from the majority“Unlike others who peddle arguments that may sound similar on the surface, our strategies have proven success, as the In ternal Revenue Service (IRS) itself (as well as U.S. Attorneys and Federal Judges) has accepted NITE’s arguments as valid, and has provided full refunds to NITE Members who use our strategies.”
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.