Boulware v. Commissioner’s Empirical Analysis
816 F.3d 133 · 2016
Citation profile
Relationships
Applies 26 U.S.C. § 7485
Relies on Byers v. Commissioner · Christopher Cross, Inc. v. United States · United States v. Boulware · 521 F. App'x 602 - HIE Holdings, Inc. v. Commissioner · Hie Holdings, Inc. v. Comm'r
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Taxpayers do not qualify for installment agreements if balance due accounts can be fully or partially satisfied by liquidating assets[.]”
6 later decisions quote this exact passage“CDP hearings are much like Collection Appeal Program (CAP) hearings in that they are informal in nature and do not require the Appeals officer or employee and the taxpayer, or the taxpayer's representative, to hold a face-to-face meeting. A CDP hearing may, but is not required to, consist of a face-to-face meeting, one or more written or oral communications between an Appeals officer or employee and the taxpayer or the taxpayer's representative, or some combination thereof.”
1 later decision quote this exact passagee.g. Brodersen v. Comm'r
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.