Howard S. Scar and Ethel M. Scar v. Commissioner of Internal Revenue’s Empirical Analysis
1987
Citation profile
86 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 231 later decisions — most recently November 2023 · most notably Shea v. Commissioner (1999), Portillo v. Commissioner (1991)
86 federal appellate · 2 district · 2 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
Applies 26 U.S.C. § 6212 · 26 U.S.C. § 6662 · 26 U.S.C. § 7453
Relies on Consumer Product Safety Commission v. GTE Sylvania, Inc. · Richards v. United States · Mahan & Rowsey, Inc. v. Oklahoma Natural Gas · Helvering v. Taylor · Reiter v. Sonotone Corp.
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 231 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the Commissioner must consider information that relates to a particular taxpayer before it can be said that the Commissioner has 'determined' a 'deficiency' in respect to that taxpayer.”
17 later decisions quote this exact passage · from the dissent“look behind a deficiency notice to question the Commissioner's motives and procedures leading to a determination.”
12 later decisions quote this exact passage · from the majority“If the Secretary determines that there is a deficiency in respect of any tax imposed ... he is authorized to send notice of such deficiency to the taxpayer by certified mail or registered mail.”
9 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.