Abrams Vr Jg Ra Rwe Hr Wm Wl v. Commissioner of Internal Revenue’s Empirical Analysis
Citation profile
8 federal appellate · 1 state decisions
How this case has been cited
Cited by 46 later decisions — most recently August 2021 · most notably Bokum II v. Commissioner of Internal Revenue, Clovis I v. Commissioner (1987)
8 federal appellate · 1 state decisions
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 Commissioner of Internal Revenue v. Gooch Milling & Elevator Co · Bridges v. United States · Commissioner v. Stewart · Olsen v. Helvering · Commissioner v. Forest Glen Creamery Co.
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Re: Liberty Financial 1983 Government Securities Trading Strategy Dear Taxpayer: Our information indicates that you invested in the above tax shelter during the above tax year. Based upon our review of that promotion, we believe that the purported tax deduction and/or credits are not allowable. We plan to review your return to determine whether you claimed such deductions and/or credits. If you did so, we will examine your return and reduce the portion of any refund due to you which is attributable to the above tax shelter promotion. If an examination results in adjustments to your return, you will be afforded the opportunity to exercise your appeal rights. The Internal Revenue Code provides, in appropriate cases, for the application of the negligence penalty under section 6653(a), the overvaluation penalty under section 6659 and/or the substantial understatement of income tax penalty under section 6661 of the Internal Revenue Code and other appropriate penalties. Our examination will determine whether these penalties are appropriate. See the back of this letter for an explanation of these penalties. If you claimed deductions and/or credits on a return already filed, you may wish to file an amended tax return.”
4 later decisions quote this exact passage · from the majority“As the letter ... made pellucidly clear, examination of the returns of each individual taxpayer had not as yet been made. The most important observation to be made about the letter is that it left no doubt that, as yet, there had been no general review of any return, no computation of any deficiency nor reduction in refunds to which the taxpayers might otherwise be entitled. It was in essence only fair warning of what the taxpayers ... might expect.”
2 later decisions quote this exact passage · from the majority“Converting a sow’s ear into a silk purse is acknowledgedly difficult. Seeking to convert into a notice of deficiency an Internal Revenue Service letter warning the petitioners that an attempt to utilize, for income tax purposes, a specific “tax shelter” would result in a redetermination leading to an assessment of a deficiency or a reduction or elimination of a refund amounts to an effort of equal audacity and equal futility.”
2 later decisions 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.