Lifter v. Commissioner’s Empirical Analysis
1973
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 90 later decisions — most recently December 2009 · most notably Frieling v. Commissioner (1983), Alta Sierra Vista, Inc. v. Commissioner (1974)
7 federal appellate ·
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. § 6212
Relies on Desist v. United States · General Electric Co. v. International Union of Electrical, Radio & Machine Workers · Kahm v. United States · Cohen v. United States · Commissioner v. Stewart
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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a taxpayer's last known address must be determined by a consideration of all relevant circumstances,”
3 later decisions quote this exact passage“Other than the address given on their return for 1968, [the Revenue Agent] received no instructions from the petitioners as to how they should be reached regarding an audit of that return. Clearly, the addresses set forth in their subsequent returns did not constitute a direction as to the address to be used to reach them regarding the 1968 return. Culver M. Budlong, 58 T.C. 850 (1972); Joseph Marcus, 12 T.C. 1071 (1949). Since the petitioners had given the 125th Street address on their return and given no directions as to what address should be used in connection with such return, [the revenue agent] chose to send the original of the notice to them at that address. * * * When all of these circumstances are considered, one surely cannot say that [the revenue agent] acted negligently. See Arlington Corp. v. Commissioner, 183 F.2d 448 (6th Cir. 1950). It might have been reasonable for him to adopt a different course— for example, to send the notice to the petitioners at their residence on Collins Avenue, but surely it must be recognized that there was reason for the course that he adopted.”
1 later decision quote this exact passage“received actual notice of the deficiency before the running of the statute of limitations and within sufficient time to prepare and file a petition with this Court.”
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.