Aberl’s Empirical Analysis

Citation profile

2 federal appellate ·

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

1. “assessed within 240 days [of the bankruptcy petition], plus any time plus 30 days during which an offer in compromise with respect to such taxes that was made within 240 days after such assessment was pending, before the date of the filing of the petition.”

   2 later decisions quote this exact passage · from the majority
   e.g. In Re Nolan · Colish v. United States (In Re Colish)

2. “`It is not the Court's role to address perceived inadequacies in [a statute].'”

   2 later decisions quote this exact passage · from the majority
   e.g. In Re: James Curtis Palmer · Cline v. General Dynamics Land System, Inc.

3. “A review of section 507's legislative history reveals Congress' concern that debtors might use an offer in compromise to delay negotiations with the IRS, following the IRS's formal assessment of unpaid taxes, until the debtors' tax liability loses priority status. The statute was therefore enacted to give the IRS 240 days to collect the taxes that are due following its formal assessment of unpaid taxes. Indeed, section 507 attempts to balance two competing interests: the debtor's interest in obtaining a fresh start free from creditors' claims; and, the IRS's interest in collecting unpaid taxes.”

   1 later decision quote this exact passage · from the majority
   e.g. In Re Nolan