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← 55 TC 709 - Rappaport v. Commissioner

Rappaport v. Commissioner’s Empirical Analysis

1971

Citation profile

23
cited by 23 later decisions
1
states following
September 1996
most recently cited

3 federal appellate · 1 district · 1 state decisions

How this case has been cited

Cited by 23 later decisions — most recently September 1996

3 federal appellate · 1 district · 1 state decisions

150197119801990decided

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

Relies on C. Louis Wood and Hallie D. Wood v. Commissioner of Internal Revenue · Wood v. Commissioner · Rich v. Commissioner · Skolski v. Commissioner of Internal Revenue · Madison 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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “there may be some logical inconsistency between the rule applicable where there is no postmark at all and the rationale of the cases which permit a taxpayer, in the situation where there is an illegible postmark, to sustain his burden by submitting evidence of time of mailing to prove when the postmark was made. * * * [Jacob L. Rappaport, 55 T.C. at 711 .]”
    1 later decision quote this exact passage
  2. “when the envelope ... would have been postmarked in the normal course of the business of the U.S. Post Office Department is irrelevant and immaterial and therefore inadmissible.”
    1 later decision quote this exact passage
  3. “[T]his Court has consistently taken the position that the requirement of a postmark is essential to obtaining the benefits of section 7502(a).”
    1 later decision quote this exact passage

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.