Thompson v. Commissioner’s Empirical Analysis
729 F.3d 869 · 2013
Citation profile
1 federal appellate ·
Relationships
Relies on Petaluma FX Partners, LLC v. Commissioner of Internal Revenue Service · 23921s Berger Transfer Storage v. Central States Southeast and Southwest Areas Pension Fund · Passmore v. Astrue · Vandenboom v. Barnhart · Bartman 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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he taxpayers are too late with this argument. The taxpayers agree that they cannot here collaterally attack the jurisdiction of the Tax Court over penalties in .this case [ie., the partner-level proceeding to adjust the tax and penalty applicable to the Thompsons’ 2001 joint .tax return]. The earlier Tax Court Decision in [the] RJT [partnership-level proceeding] is res judicata, on the applicability of penalties here_ The decision of the Tax Court dismissing this [partner-level proceeding] for lack of jurisdiction should be reversed as to jurisdiction over the deficiency determination.-”
1 later decision quote this exact passage · from the majority“outside basis is an affected item that must be determined at the partner level.”
1 later decision quote this exact passage · from the majority“the tax court clearly determined Thompson's outside basis to be zero”
1 later decision quote this exact passage · from the concurrence
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.