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← 77 TC 334 - Doncaster v. Commissioner

Doncaster v. Commissioner’s Empirical Analysis

1981

Citation profile

197
cited by 197 later decisions
October 2018
most recently cited

6 federal appellate ·

How this case has been cited

Cited by 197 later decisions — most recently October 2018 · most notably Dahlstrom v. Commissioner (1985), Marshall v. Commissioner (1985)

6 federal appellate ·

10101981199020002010decided

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 Grosshandler v. Commissioner · Stratton v. Commissioner · Marcus v. Commissioner · Estate of Beck v. Comm'r · Gilday 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 197 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “within the meaning of Rule 37(c) ; in our judgment, their deemed admission more than satisfies the respondent's burden of proof. Marcus v. Commissioner, 70 T.C. 562 , 577 (1978) ; cf. Ritchie v. Commissioner, 72 T.C. 126 , 129 (1979) . We are reinforced in our conclusion by the numerous holdings that fraud is a question of fact--albeit an ultimate question of fact. E.g., Grosshandler v. Commissioner, supra at 19. Even if we were to take the view that, in the context of this case, the ultimate issue of fraud should not be considered a pure question of fact, it is at least a question of”
    2 later decisions quote this exact passage
  2. “specified allegations in the answer be deemed admitted,”
    2 later decisions quote this exact passage
  3. “So that there will be no misunderstanding, we emphasize that the deemed admissions of the allegations of paragraphs 7(a) through 7(g) are also of importance in respect of respondent’s ability to establish his fraud case; he has the burden of proving the facts necessary to show an underpayment (to which the addition to tax for fraud attaches) and may not rely upon petitioner’s failure to produce evidence in order to carry his (respondent’s) burden in that respect. [ 77 T. C. at 337-338 . Citations omitted.]”
    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.