Brown v. Commissioner’s Empirical Analysis
693 F.3d 765 · 2012
Citation profile
Relationships
Applies 26 U.S.C. § 163 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6662 · 26 U.S.C. § 6664 · 26 U.S.C. § 72
Relies on United States v. Boyle · Kikalos v. Commissioner · Indianapolis Life Insurance Company v. United States · Prairie States Life Insurance v. United States · TIFD III-E, Inc. 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Generally [reliance on the § 6664(c)(1) exception] requires that [the taxpayer] have obtained an opinion from an accountant or lawyer.”
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.