Cropper v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate · 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[W]hen the Tax Court decision rests on its review of an Office of Appeals’ determination following a CDP hearing, we apply the same standards as the Tax Court. Thus, we review the Office of Appeals’ determinations about challenges to the amount of the underlying tax liability de novo and its administrative determinations unrelated to the amount of tax liability for abuse of discretion.”

   2 later decisions quote this exact passage · from the majority
   e.g. Portwine v. Commissioner · LG Kendrick, LLC v. Commissioner

2. “evidence corroborating an actual timely mailing of the notice of deficiency.”

   1 later decision quote this exact passage · from the majority
   e.g. Noyes v. Comm'r

3. “presumptive proof of a valid assessment.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Meyer