Hallam v. Murphy’s Empirical Analysis
1983
Citation profile
19
cited by 19 later decisions
December 1988
most recently cited
8 federal appellate ·
Relationships
Applies 26 U.S.C. § 7430
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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) In General.—In the case of any civil proceeding which is— (1) brought by or against the United States in connection with the determination, collection, or refund of any tax, interest, or penalty under this title, and (2) brought in a court of the United States (including the Tax Court and the United States Claims Court), the prevailing party may be awarded a judgment for reasonable litigation costs incurred in such proceeding. (b) Limitations.— (1) Maximum dollar amount.—The amount of reasonable litigation costs which may be awarded under subsection (a) with respect to any prevailing party in any civil proceeding shall not exceed $25,000. (2) Requirement that administrative remedies be exhausted.—A judgment for reasonable litigation costs shall not be awarded under subsection (a) unless the court determines that the prevailing party has exhausted the administrative remedies available to such party within the Internal Revenue Service.”
2 later decisions quote this exact passage · from the majority“the continued assertion of a position with knowledge that the position is based upon an erroneous assumption is per se unreasonable”
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.