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← 62 TC 543 - O'Brien v. Commissioner

O'Brien v. Commissioner’s Empirical Analysis

1974

Citation profile

51
cited by 51 later decisions
May 2013
most recently cited

3 federal appellate ·

How this case has been cited

Cited by 51 later decisions — most recently May 2013 · most notably Monge v. Commissioner (1989), Abeles v. Commissioner (1988)

3 federal appellate ·

27019741980199020002010decided

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

Relies on Mullane v. Central Hanover Bank & Trust Co. · Phillips v. Commissioner · City of New York v. New York, New Haven & Hartford Railroad · Schroeder v. City of New York · Walker v. City of Hutchinson

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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “If the mailing of a notice of deficiency to a taxpayer is to be any more than an empty gesture, there should be some reasonable expectation that the taxpayer will receive it.”
    1 later decision quote this exact passage

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.