Brinkley v. Commissioner’s Empirical Analysis
808 F.3d 657 · 2015
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 1 (Airport and Airway Extension Act of 2008) · 26 U.S.C. § 6201 · 26 U.S.C. § 6662 · 26 U.S.C. § 6664 · 26 U.S.C. § 7482 · 26 U.S.C. § 7491
Relies on Anderson v. City of Bessemer City · Welch v. Helvering · Knudsen v. Comm'r · Blodgett v. Commissioner · Dobson 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he most important factor is the extent of the taxpayer's effort to assess his [or her] proper liability in light of all the circumstances.”
2 later decisions quote this exact passage · from the majority“The taxpayer bears the burden of proof on this defense, and the determination of whether the taxpayer has successfully discharged this burden 'is made on a case-by-case basis, taking into account all pertinent facts and circumstances.'”
1 later decision quote this exact passage · from the majority“The 'characterization of a transaction for tax purposes is a question of law subject to de novo review, but the particular facts from which that characterization is made are reviewed for clear error.'”
1 later decision 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.