Michael C. Hollen v. CIR’s Empirical Analysis
2002
Citation profile
4
cited by 4 later decisions
January 2014
most recently cited
Relationships
Applies 26 U.S.C. § 6653
Relies on Herrington v. Commissioner · LeFever v. Commissioner · Beltzer v. United States
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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the taxpayer has made a representation or reported an item for tax purposes in one year, (2) the Commissioner has acquiesced in or relied on that fact for that year, and (3) the taxpayer desires to change the representation, previously made, in a later year after the statute of limitations on assessments bars adjustments for the initial tax year.”
1 later decision quote this exact passage · from the majoritye.g. Blonien v. Comm'r
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.