Frieling v. Commissioner’s Empirical Analysis
1983
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 180 later decisions — most recently January 2019 · most notably Monge v. Commissioner (1989), Hoyle v. Comm'r (2008)
4 federal appellate ·
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 Desist v. United States · Detenber v. American Universal Insurance Co · Bradshaw v. Sea World, Inc · Alta Sierra Vista, Inc. v. Commissioner · Commissioner v. Stewart
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 180 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“pertains to * * * [the Commissioner's] knowledge rather than to what may in fact be the taxpayer's most current address.”
9 later decisions quote this exact passage“from the taxpayer directing respondent to use a different address, respondent is entitled to treat the address shown on the return for which the notice of deficiency is being issued as the taxpayer's”
4 later decisions quote this exact passage“the address to which, in light of all the facts and circumstances, respondent reasonably believed the taxpayer wished the notice of deficiency to be sent.”
4 later decisions quote this exact passage
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.