Ferguson v. Commissioner’s Empirical Analysis
568 F.3d 498 · 2009
Citation profile
3 federal appellate ·
Relationships
Applies 26 U.S.C. § 166 · 26 U.S.C. § 6213 · 26 U.S.C. § 6214 · 26 U.S.C. § 6330 · 26 U.S.C. § 6501 · 26 U.S.C. § 6651 · 26 U.S.C. § 6662 · 26 U.S.C. § 7442
Relies on Begier v. Internal Revenue Service · United States v. Dalm · Swanson v. Commissioner · Continental Equities, Inc. v. Commissioner · In re Cassidy
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“unavailability (to the taxpayer) of “information or records does not necessarily establish reasonable cause for failure to file timely a tax return,” because even without full information, “[a] taxpayer is required to file timely based upon the best information available and to file thereafter an amended return if necessary.””
1 later decision 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.