Reynolds v. Commissioner’s Empirical Analysis
2002
Citation profile
39
cited by 39 later decisions
April 2018
most recently cited
15 federal appellate ·
Relationships
Applies 26 U.S.C. § 7121
Relies on Welch v. Helvering · Indopco, Inc. v. Commissioner · Commissioner of Internal Revenue v. Flowers · United States v. Gilmore · Lykes 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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“includes any careless, reckless, or intentional disregard. Sec. 6662(c) . No penalty shall be imposed if it is shown that there was reasonable cause for the underpayment and the taxpayer acted in good faith with respect to the underpayment. Sec. 6664(c) . The determination of whether a taxpayer acted with reasonable cause and in good faith is made on a case-by-case basis, taking into account all pertinent facts and circumstances. The most important factor is the extent of the taxpayer's effort to assess the taxpayer's proper tax liability.”
4 later decisions quote this exact passage · from the majority“Circumstances that may indicate reasonable cause and good faith include an honest misunderstanding of fact or law that is reasonable in light of all the facts and circumstances, including the experience, knowledge and education of the taxpayer.”
3 later decisions quote this exact passage · from the majority“a high degree of probative value to elevate such statement”
3 later decisions 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.