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← 71 TC 1028 - Baron v. Commissioner

Baron v. Commissioner’s Empirical Analysis

1979

Citation profile

20
cited by 20 later decisions
March 2019
most recently cited

1 federal appellate · 1 district ·

How this case has been cited

Cited by 20 later decisions — most recently March 2019

1 federal appellate · 1 district ·

16019791980199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Bostwick v. United States · Hannan v. Commissioner · Dolan v. Commissioner · Gwilliam v. United States · Cohen v. Gross

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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “In Sharpe, we explained the Court’s interpretation of section 6871: "It is our present view that by establishing a different method for assessment and collection of taxes where bankruptcy intervenes, Congress intended that 'tax’ matters in their entirety be settled by the bankruptcy court under bankruptcy procedures instead of by the Tax Court under the procedures set forth in sections 6212(a) and 6213(a), except where the Tax Court petition antedates the petition in bankruptcy. * * * [Emphasis added.]””
    1 later decision quote this exact passage
  2. “As discussed in Sharpe and Tatum, present bankruptcy law provides the bankrupt taxpayer the right to have his tax liability adjudicated in the bankruptcy proceeding even though the Commissioner has filed no proof of claim for the tax. For a recent illustration, see In re Harper, 580 F.2d 165 (5th Cir. 1978). That is, sections 2a(2A) and 17(c) of the Bankruptcy Act afford the taxpayer a prepayment hearing without regard to whether the Commissioner files a claim. * * *”
    1 later decision quote this exact passage
  3. “Whether or not the deficiency and addition to tax here were, or ever will be, actually litigated in the bankruptcy proceeding, the critical point here is that petitioner had the opportunity to litigate those claims in a prepayment forum. * * *”
    1 later decision quote this exact passage

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.