Bliss v. Commissioner’s Empirical Analysis
1995
Citation profile
15 federal appellate · 1 district ·
How this case has been cited
Cited by 37 later decisions — most recently December 2012 · most notably Cheshire v. Commissioner (2002), Reser v. Commissioner (1997)
15 federal appellate · 1 district ·
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. § 6013
Relies on Sanders v. United States · Stevens v. Commissioner · Price v. Commissioner · Sonnenborn v. Commissioner · Hayman 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“because, ordinarily, they predict what a prudent person would realize regardless of the other spouse's evasiveness or deceit.”
3 later decisions quote this exact passage · from the majority“§ 6013(e) Spouse relieved of liability in certain cases.— (1) In general. — Under regulations prescribed by the Secretary, if— (A) a joint return has been made under this section for a taxable year, (B) on such return there is a substantial understatement of tax attributable to grossly erroneous items of one spouse, (C) the other spouse establishes that in signing the return he or she did not know, and had no reason to know, that there was such substantial understatement, and (D) taking into account all the facts and circumstances, it is inequitable to hold the other spouse liable for the deficiency in tax for such taxable year attributable to such substantial understatement, then the other spouse shall be relieved of liability for tax (including interest, penalties, and other amounts) for such taxable year to the extent such liability is attributable to such substantial understatement.”
1 later decision quote this exact passage · from the majority“of the substantial understatement include: (1) the spouse's level of education; (2) the spouse's involvement in the family's business and financial affairs; (3) the presence of expenditures that appear lavish or unusual when compared to the family's past levels of income, standard of living, and spending patterns; and (4) the culpable spouse's evasiveness and deceit concerning the couple's finances. [Citations omitted.]”
1 later decision quote this exact passage · from the majoritye.g. Doyel 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.