Borg-Warner Corp. v. Commissioner’s Empirical Analysis
660 F.2d 324 · 1981
Citation profile
4 federal appellate · 1 district ·
How this case has been cited
Cited by 24 later decisions — most recently April 2011
4 federal appellate · 1 district ·
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. § 6501
Relies on Donaldson v. United States · United States v. National Bank · United States v. Bailey · United States v. Ahrens · Lesser v. United States
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“mailing by the Internal Revenue Service of written notification to the taxpayer(s) of termination of Appellate Division consideration”
4 later decisions quote this exact passage“The purpose of agreements extending the statutory limitations period is to allow a taxpayer to seek compromises of its asserted tax liability. See United States v. Hernan, 186 F.Supp. 98 (E.D.N.Y.1960). When the possibilities of settlement have been exhausted, the quid pro quo for the extension of this limitations period disappears.”
2 later decisions quote this exact passage“.02 With the exception of the mailing of a notice of deficiency, written notification by the Service to the taxpayer(s) of termination of Service consideration can only be made using Form 872-T.”
1 later decision quote this exact passage · from the dissent
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.