Calloway v. Commissioner’s Empirical Analysis
691 F.3d 1315 · 2012
Citation profile
4 federal appellate ·
Relationships
Applies 26 U.S.C. § 1058 · 26 U.S.C. § 6012 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6651 · 26 U.S.C. § 6662 · 26 U.S.C. § 6664 · 26 U.S.C. § 7491
Relies on HIGBEE v. COMMISSIONER OF INTERNAL REVENUE · Crane v. Commissioner · Landreth Timber Co. v. Landreth · Commissioner v. Brown · Commissioner v. Tufts
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“must come forward with sufficient evidence indicating that it is appropriate to impose the relevant penalty.”
2 later decisions quote this exact passage · from the majority“whether the contract creates a present obligation on the seller to execute and deliver a deed and a present obligation on the purchaser to make payments”
1 later decision quote this exact passage · from the majority“10 percent of the tax required to be shown on the return.”
1 later decision quote this exact passage · from the majoritye.g. Avrahami 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.