Starnes v. Commissioner’s Empirical Analysis
680 F.3d 417 · 2012
Citation profile
10 federal appellate · 1 state decisions
Relationships
Applies 26 U.S.C. § 6901 · 26 U.S.C. § 6902
Relies on Erie Co v. Tompkins · Hernandez v. New York · Frank Lyon Co. v. United States · Commissioner v. Stern · Rice's Toyota World, Inc. 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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“if the Former Shareholders were on inquiry notice of MidCoast's plans and failed to make reasonably diligent inquiry, they are charged with the knowledge they would have acquired had they undertaken the reasonably diligent inquiry required by the known circumstances.”
3 later decisions quote this exact passage · from the majority“First, did the [plaintiffs] have actual knowledge of facts that would have led a reasonable person concerned about [GNC’s] solvency to inquire further into [Battery Street’s] post-closing plans? Second, if the [plaintiffs] were thereby on “inquiry notice,” whether the inquiry a reasonably diligent, similarly-situated person would have undertaken [would have] revealed [Battery Street’s] plan to leave [GNC] unable to pay its [2000] taxes?”
2 later decisions quote this exact passage · from the majority“on the same basis as decisions in civil bench trials in United States district courts.”
2 later decisions 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.