AD Global Fund, LLC ex rel. North Hills Holding, Inc. v. United States’s Empirical Analysis
481 F.3d 1351 · 2007
Citation profile
14 federal appellate ·
How this case has been cited
Cited by 47 later decisions — most recently August 2021 · most notably Keller v. Commissioner (2009), Keener v. United States (2009)
14 federal appellate ·
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. § 6221 · 26 U.S.C. § 6223 · 26 U.S.C. § 6226 · 26 U.S.C. § 6229 · 26 U.S.C. § 6231 · 26 U.S.C. § 6501
Relies on Barnhart v. Sigmon Coal Co. · Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner · Andantech Llc v. Commissioner of Internal Revenue · US Steel Group Bethlehem Steel Corporation v. United States Ag Der Dillinger Huttenwerke
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General rule.—Except as otherwise provided in this section, the period for assessing any tax imposed by subtitle A [Income Taxes] with respect to any person which is attributable to any partnership item (or affected item) for a partnership taxable year shall not expire before the date which is 3 years after the later of— (1) the date on which the partnership return for such taxable year was filed, or (2) the last day for filing such return for such year (determined without regard to extensions).”
5 later decisions quote this exact passage · from the majority“(3) Partnership item. — The term “partnership item” means, with respect to a partnership, any item required to be taken into account for the partnership’s taxable year under any provision of subtitle A [of the Tax Code] to the extent regulations prescribed by the Secretary provide that, for purposes of this subtitle, such item is more appropriately determined at the partnership level than at the partner level. (4) Nonpartnership item. — The term “nonpartnership item” means an item which is (or is treated as) not a partnership item. (5) Affected item. — The term “affected item” means any item to the extent such item is affected by a partnership item.”
2 later decisions quote this exact passage · from the majority“[IRC] § 6229(a) unambiguously sets forth a minimum period for assessments of partnership items that may extend the regular statute of limitations in § 6501. Section 6501 explicitly provides that it applies to any tax imposed by the title, which would include tax imposed for partnership items ..., [and][n]o exception is provided for assessment of taxes for partnership items. 30”
2 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.