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← 74 TC 743 - Graff v. Commissioner

Graff v. Commissioner’s Empirical Analysis

1980

Citation profile

97
cited by 97 later decisions
2
states following
September 2020
most recently cited

10 federal appellate · 1 district · 3 state decisions

How this case has been cited

Cited by 97 later decisions — most recently September 2020 · most notably Reynolds v. Commissioner (1988), Boulez v. Commissioner (1981)

10 federal appellate · 1 district · 3 state decisions

42019801990200020102020decided

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

Applies 12 U.S.C. § 1715L (Emergency Low Income Housing Preservation Act of 1987) · 12 U.S.C. § 1715Z · 12 U.S.C. § 1715Z · 26 U.S.C. § 6653

Relies on Federal Crop Ins Corporation v. Merrill · Chrysler Corporation v. Brown · Commissioner of Internal Revenue v. Glenshaw Glass Company · Eisner v. Macomber · United Housing Foundation, Inc. v. Forman

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

  1. “Quasi-Estoppel and Abuse of Discretion as Applied Against the United States in Federal Tax Controversies”
    3 later decisions quote this exact passage
  2. “even where a taxpayer may have relied to his detriment on the * * * [IRS'] mistake.”
    2 later decisions quote this exact passage
  3. “By its clear wording, Section 56 of the Internal Revenue Code imposes a tax '[in] addition to the other taxes' imposed under the income tax provisions. The Legislative History of the provision supports this language for congress's intention was not to give tax relief, but rather to impose an additional tax on high income individuals with large amounts of non-wage income.”
    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.