Doggett v. Commissioner’s Empirical Analysis
1976
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 25 later decisions — most recently May 2018 · most notably Dixson Int'l Service Corp. v. Commissioner (1990), Bouterie v. Commissioner (1994)
1 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. § 453
Relies on Commissioner v. Sunnen · O’Callahan v. Parker, Warden · Pauling v. McElroy · United States v. Peltier · Shiosaki 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is also well established that in tax litigation the Commissioner may, in notices of deficiency, present alternative claims for deficiencies when there is a basis for doing so.”
2 later decisions quote this exact passage“urge[d] the Commissioner ... to indicate clearly to the taxpayer [when a] claim is being presented in the alternative and that there is no intention to tax the same income twice.”
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.