Hiley v. United States’s Empirical Analysis

Citation profile

17 federal appellate · 5 district · 1 state decisions

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 40 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—”

   3 later decisions quote this exact passage
   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

2. “Within 90 days, or 150 days if the notice is addressed to a person outside the United States, after the notice of deficiency authorized in section 6212 is mailed ... the taxpayer may file a petition with the Tax Court for a redeter-mination of the deficiency. Except as otherwise provided in section 6851, 6852, or 6861 no assessment of a deficiency in respect of any tax imposed by subtitle A, or B, chapter 41, 42, 43, or 44 and no levy or proceeding in court for its collection shall be made, begun, or prosecuted until such notice has been mailed to the taxpayer, nor until the expiration of such 90-day or 150-day period, as the case may be, nor, if a petition has been filed with the Tax Court, until the decision of the Tax Court has become final.”

   2 later decisions quote this exact passage · from the concurrence
   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

3. ““Determination by the district court— Within 20 days after an action is commenced ..., the district court shall determine whether or not— (A) the making of the assessment under Section 6851, 6861, or 6862, as the case may be, is reasonable under the circumstances, and (B) the amount so assessed or demanded as a result of the action taken under section 6851, 6861, or 6862, is appropriate under the circumstances.” 26 U.S.C. § 7429 (b).”

   2 later decisions quote this exact passage · from the concurrence
   e.g. Stebco Inc. v. United States · Stebco Incorporated Sa Cv Sa Cv Sa Cv Sa Cv v. United States