Rhone-Poulenc Surfactants and Specialties Lp Gaf Chemicals Corporation Partner Other Than the Tax Matters Partner v. Commissioner of Internal Revenue’s Empirical Analysis

Citation profile

3 federal appellate · 2 district · 4 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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The TEFRA partnership provisions were enacted in 1982 in response to the mushrooming administrative problems experienced by the Internal Revenue Service in auditing returns of partnerships, particularly tax shelter partnerships with numerous partners. Under these procedures, the tax treatment of partnership items is determined at the partnership level in a unified partnership proceeding rather than in separate proceedings for each partner.”

   1 later decision quote this exact passage · from the majority
   e.g. 72 Fed. Cl. 95 - Schumacher Trading Partners II v. United States

2. “[t]o satisfy Article Ill’s case or controversy requirement, an action must present (1) a legal controversy that is real and not hypothetical, (2) a legal controversy that affects an individual in a concrete manner so as to provide the factual predicate for reasoned adjudication, and (3) a legal controversy so as to sharpen the issues for judicial resolution.”

   1 later decision quote this exact passage · from the majority
   e.g. 146 F. Supp. 2d 706 - Laborers Local 1298 Annuity Fund Ex Rel. Rite Aid Corp. v. Grass

3. “This Court is without power to give advisory opinions. It has long been its considered practice not to decide abstract, hypothetical or contingent questions.”

   1 later decision quote this exact passage · from the majority
   e.g. 146 F. Supp. 2d 706 - Laborers Local 1298 Annuity Fund Ex Rel. Rite Aid Corp. v. Grass