Pyo v. Commissioner’s Empirical Analysis
1984
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 146 later decisions — most recently May 2020 · most notably Monge v. Commissioner (1989), King v. Commissioner (1988)
8 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 Parham v. Cortese · Golsen v. Commissioner · Golsen v. Commissioner · Cool Fuel, Inc. v. Connett · United States v. Zolla
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 146 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the taxpayer's last permanent address or legal residence known by the Commissioner, or the last known temporary address of a definite duration to which the taxpayer has directed the Commissioner to send all communications during such period.”
3 later decisions quote this exact passage“It is * * * relevant to observe that at the time the notice of deficiency was first mailed to [the taxpayers] at their [F Street] address, the Los Angeles District Director’s Office employees who mailed this document to petitioners had access to the Fresno Service Center computer system which, at that time, contained their [C Street] address. Although, at this juncture, we will not attribute the information contained in this computer system to such employees and require them to consult this system in order to satisfy the “last known address” investigative responsibilities, the time may come when this is appropriate. See Weinroth v. Commissioner, 74 T.C. 430 , 437 n. 7 (1980). * * * [Pyo v. Commissioner, supra at 637 n. 10.]”
1 later decision quote this exact passage“An innocent taxpayer should not be penalized because the tax collector neglects to tell his right hand what his left hand is doing.”
1 later decision 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.