Morrison v. Commissioner’s Empirical Analysis
565 F.3d 658 · 2009
Citation profile
5 federal appellate · 1 state decisions
Relationships
Applies 26 U.S.C. § 7430 · 28 U.S.C. § 2412 · 42 U.S.C. § 1988 · 42 U.S.C. § 3612 (§ 812 of the Fair Housing Act (Title VIII, Civil Rights Act of 1968))
Relies on Leocal v. Ashcroft · Commissioner, Immigration & Naturalization Service v. Jean · Huffman v. Commissioner · Cornella v. Schweiker · Dennis v. Chang
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] taxpayer can 'incur' attorneys' fees if he assumes either: (1) a noncontingent obligation to repay the fees advanced on his behalf at some later time; or (2) a contingent obligation to repay the fees in the event of their eventual recovery.”
2 later decisions quote this exact passage · from the majority“fees if the fees are first paid by a third party, it did not sort out the precise nature of the relationship between Caspian and Morrison, and so did not determine whether Caspian agreed to pay some or all of Morrison's fees as consideration for an earlier transaction, or whether Morrison assumed a contingent or noncontingent repayment obligation. We therefore remand to the Tax Court to apply the definition we have adopted of”
1 later decision quote this exact passage · from the majoritye.g. Morrison v. Comm'r“Id. Its review of the written disclosure agreement (i.e., the engagement letter) revealed that it is silent on precisely how the payment and reimbursement of fees were to be handled. The Court of Appeals stated: Because the Tax Court took the view that a litigant can never”
1 later decision quote this exact passage · from the majoritye.g. Morrison 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.