Haag v. Shulman’s Empirical Analysis
683 F.3d 26 · 2012
Citation profile
3 federal appellate · 1 district · 1 state decisions
Relationships
Applies 26 U.S.C. § 6013 · 26 U.S.C. § 6015
Relies on Commissioner v. Sunnen · Federated Department Stores, Inc. v. Moitie · Kale v. Combined Insurance Co. of America · George Havercombe v. Department of Education of the Commonwealth of Puerto Rico · Lantz 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In any event, we are constrained to agree with the government’s reasoning that the terms of Notice 2011-70 would be inapplicable to Haag even if her claim were not precluded by res judicata.... In Haag’s case, the IRS never stipulated that § 6015(f)’s two-year deadline constituted the sole obstacle to her claim. On the contrary, we note that in the Haag I litigation, the government argued that Haag administratively waived her claim by not articulating her request for relief before the Secretary prior to raising it at the district court.”
1 later decision quote this exact passage · from the majority“Taxpayers who file joint returns are held jointly and severally liable for liabilities that flow from those submissions. “Innocent spouse” relief provisions in the tax code offer a narrow exception to this arrangement. Under these, the tax code exempts a joint filer who “did not know or have reason to know that there was an understatement on the tax return” from joint and several liability.”
1 later decision quote this exact passage · from the majoritye.g. In re Mason“Nor are the res judicata consequences of a final, unappealed judgment on the merits altered by the fact that the judgment may have been wrong or rested on a legal principle subsequently overruled in another case.”
1 later decision quote this exact passage · from the majoritye.g. Haag v. Comm'r
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.