Dalton v. Commissioner’s Empirical Analysis
682 F.3d 149 · 2012
Citation profile
6 federal appellate ·
Relationships
Applies 26 U.S.C. § 6330 · 26 U.S.C. § 6331 · 26 U.S.C. § 6672 · 26 U.S.C. § 7430
Relies on Montana v. United States · Phillips v. Commissioner · G. M. Leasing Corp. v. United States · Phillips v. Commissioner · Drye 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“consider[ing] whether the factual and legal conclusions reached at a CDP hearing are reasonable, not whether they are correct.”
2 later decisions quote this exact passage · from the majority“(1) whether inadequate or no consideration was paid by the nominees; (2) whether the properties were placed in the nominees’ names in anticipation of a lawsuit or other liability while the transferor remains in control of the property; (3) whether there is a close relationship between the nominees and the transfer- or; (4) failure to record the conveyances; (5) whether the transferor retained possession; and (6) whether the transferor continues to enjoy the benefits of the transferred property.”
1 later decision quote this exact passage · from the majority“the IRS is tasked with deciding whether it is reasonable to proceed with its intended collection action.” Id.; see also 26 U.S.C. § 6330 (c)(3) (the proposed levy must”
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.