Hall v. Commissioner’s Empirical Analysis

Citation profile

9 federal appellate · 1 district ·

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

1. “Any determination made by a court under this section shall be final and conclusive and shall not be reviewed by any other court.” We agree with the Commissioner that § 7429(f) does not apply to dismissals for lack of jurisdiction. Pursuant to § 7429(b)(3), "determinations” made by a district court or the Tax Court consist of findings regarding the reasonableness and appropriateness of the jeopardy assessment or levy. In the absence of any contrary indication, the use of the same word—”

   2 later decisions quote this exact passage · from the majority
   e.g. Friko Corp. v. Commissioner · Friko Corporation, Johnny Daccarett-Ghia, as Alleged Alter Ego or Nominee of Friko Corporation v. Commissioner of Internal Revenue