Hartmann v. Commissioner’s Empirical Analysis
638 F.3d 248 · 2011
Citation profile
2 federal appellate ·
Relationships
Applies 26 U.S.C. § 6330 · 26 U.S.C. § 7482
Relies on Craig v. Comm'r · Olsen v. United States · Kindred v. Commissioner · Christopher Cross, Inc. v. United States · Connecticut General Life Insurance 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The record indicates that respondent’s Appeals Office considered all of petitioner’s contentions, verified compliance with all applicable laws and regulations, and considered whether the proposed collection actions balanced the need for efficient tax collection with petitioner’s concern that they be no more intrusive than necessary. We conclude that the Appeals Office did not abuse its discretion in sustaining the levy, and, as a result, respondent may proceed with collection action as determined in the notice of determination upon which this case is based.”
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.