Crispin v. Commissioner’s Empirical Analysis
708 F.3d 507 · 2013
Citation profile
3 federal appellate ·
Relationships
Applies 26 U.S.C. § 1012 · 26 U.S.C. § 1361 · 26 U.S.C. § 165 · 26 U.S.C. § 465 · 26 U.S.C. § 6211 · 26 U.S.C. § 6662 · 26 U.S.C. § 6664 · 26 U.S.C. § 7482
Relies on Bixby v. Commissioner · Neonatology Associates Pa v. Commissioner of Internal Revenue · United States v. Tomko · Commissioner v. Tufts · Heasley 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Circumstances that may indicate reasonable cause and good faith include an honest misunderstanding of fact or law that is reasonable in light of all of the facts and circumstances, including the experience, knowledge, and education of the taxpayer.”
3 later decisions quote this exact passage · from the majority“[i]ndicia of objective economic substance include whether the loss claimed was real or artificial, whether the transaction was part of a prepackaged strategy marketed to shelter taxable gain, and whether the transaction has any practicable economic effects other than the creation of income tax losses.”
2 later decisions quote this exact passage · from the majority“[T]here was no potential for profit, because the interest rate charged on the CARDS Loan was greater than the interest paid on the proceeds deposited as collateral at [the facilitating bank].”
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.