UTAM, Ltd. v. Commissioner’s Empirical Analysis
645 F.3d 415 · 2011
Citation profile
1 district ·
Relationships
Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6221 · 26 U.S.C. § 6223 · 26 U.S.C. § 6226 · 26 U.S.C. § 6229 · 26 U.S.C. § 6231 · 26 U.S.C. § 6501
Relies on Colony, Inc. v. Commissioner · Rhone-Poulenc Surfactants & Specialties, L.P. v. Commissioner · Petaluma FX Partners, LLC v. Commissioner of Internal Revenue Service · Zlotnick v. TIE Communications · Andantech Llc v. Commissioner of Internal Revenue
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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Omission from gross income If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.”
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.