Alpha I, L.P. ex rel. Sands v. United States’s Empirical Analysis
682 F.3d 1009 · 2012
Citation profile
5 federal appellate ·
Relationships
Applies 26 U.S.C. § 465 · 26 U.S.C. § 6031 · 26 U.S.C. § 6223 · 26 U.S.C. § 6226 · 26 U.S.C. § 6231 · 26 U.S.C. § 664 · 26 U.S.C. § 6662 · 26 U.S.C. § 701
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Todd v. Commissioner · McCrary v. Commissioner · Gilman v. Commissioner · Illes 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he portion of a tax underpayment that is attributable to a valuation overstatement will be determined after taking into account any other proper adjustments to tax liability. Thus, the underpayment resulting from a valuation overstatement will be determined by comparing the taxpayer’s (1) actual tax liability (i.e., the tax liability that results from a proper valuation and which takes into account any other proper adjustments) with (2) actual tax liability as reduced by taking into account the valuation overstatement. The difference between these two amounts will be the underpayment that is attributable to the valuation overstatement.”
4 later decisions quote this exact passage · from the majority“[t]he Blue Book, in sum, offers the unremarkable proposition that, when the IRS disallows two different deductions, but only one disallowance is based on a valuation misstatement, the valuation misstatement penalty should apply only to the deduction taken on the valuation misstatement, not the other deduction, which is unrelated to valuation misstatement. The court in Todd mistakenly applied that simple rule to a situation in which the same deduction is disallowed based on both valuation misstatement- and non-valuation-misstatement theories. * * * [Id. at 1029.]”
4 later decisions quote this exact passage · from the majority“Assume ... an individual files a joint return showing taxable income of $ 40,000 and tax liability of $ 9,195. Assume, further, that a $ 30,000 deduction which was claimed by the taxpayer as the result of a valuation overstatement is adjusted down to $ 10,000, and that another deduction of $ 20,000 is disallowed totally for reasons apart from the valuation overstatement. These adjustments result in correct taxable income of $ 80,000 and correct tax liability of $ 27,505. Accordingly, the underpayment due to the valuation overstatement is the difference between the tax on $ 80,000 ($ 27,505) and the tax on $ 60,000 ($ 17,505) ... or $ 9,800.”
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.