106 Ltd. v. Commissioner’s Empirical Analysis
684 F.3d 84 · 2012
Citation profile
5 federal appellate · 1 state decisions
Relationships
Applies 26 U.S.C. § 6226 · 26 U.S.C. § 6662 · 26 U.S.C. § 6664 · 26 U.S.C. § 7482
Relies on Anderson v. City of Bessemer City · United States v. Boyle · Pasternak v. Commissioner · Stobie Creek Investments LLC v. United States · Petaluma FX Partners, LLC v. Commissioner of Internal Revenue Service
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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'an adviser who participated in structuring the transaction or is otherwise related to, has an interest in, or profits from the transaction'”
7 later decisions quote this exact passage · from the majority“such reliance was reasonable and the taxpayer acted in good faith.”
2 later decisions quote this exact passage · from the majority“the improbable tax advantages offered by the tax shelter”
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.