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← 25 F.3d 1289 - Park v. Commissioner

Park v. Commissioner’s Empirical Analysis

25 F.3d 1289 · 1994

Citation profile

72
cited by 72 later decisions
April 2017
most recently cited

27 federal appellate ·

How this case has been cited

Cited by 72 later decisions — most recently April 2017 · most notably Cheshire v. Commissioner (2002), Westbrook v. Commissioner (1995)

27 federal appellate ·

510199420002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Applies 26 U.S.C. § 6013

Relies on Brown v. Gardner · Director, Office of Workers' Compensation Programs v. Broyles · In re Disbarment of Goldman · Sanders v. United States · Purcell 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 72 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[A] spouse seeking innocent spouse relief cannot turn 'a blind eye' to, by preferring not to know of, a deduction fully disclosed on a return when the amount of that deduction is so large that it would reasonably put her on notice that she should inquire further.”
    3 later decisions quote this exact passage · from the majority
    e.g. Estate of Jones v. Commissioner · Warren v. Commissioner
  2. “a reasonably prudent taxpayer in his or her position, at the time he or she signed the return, could be expected to know that the return contained an understatement or that further investigation was warranted.”
    3 later decisions quote this exact passage · from the majority
    e.g. Haltom v. Comm'r · Smith v. Comm'r
  3. “in her position would be led to question the legitimacy of the deduction.”
    3 later decisions quote this exact passage · from the majority
    e.g. Melinda B. Resser v. Commissioner of Internal Revenue · Resser v. Commissioner

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.