Sliwa v. Commissioner’s Empirical Analysis
1988
Citation profile
45 federal appellate · 3 district ·
How this case has been cited
Cited by 87 later decisions — most recently July 2005 · most notably Huffman v. Commissioner (1992), Sher v. Commissioner (1988)
45 federal appellate · 3 district ·
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. § 7430 · 26 U.S.C. § 7482
Relies on New Colonial Ice Co. v. Helvering · Vandygriff v. Phillips · Hannahville Indian Community v. United States · United States v. McConney · Estate of Charles T. Franklin, Deceased v. Commissioner of Internal Revenue
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 87 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“That case held that, under the 1982 version of section 7430, in making the determination that the position of the United States in the proceeding was unreasonable,”
6 later decisions quote this exact passage · from the majority“[I]f a taxpayer is forced to resort to litigation by an unreasonable IRS administrative position, § 7430 does not require the captious position to be ignored. The taxpayer must be the plaintiff in a Tax Court proceedings[ ]. If the IRS takes an arbitrary position and forces a taxpayer to file a suit, then, after the papers have been filed ... the taxpayer should be permitted to recover the cost of suing.”
5 later decisions quote this exact passage · from the majority“(4) Position of united states. — The term “position of the United States” includes— (A) the position taken by the United States in the civil proceeding, and (B) any administrative action or inaction by the District Counsel of the Internal Revenue Service (and all subsequent administrative action or inaction) upon which such proceeding is based.”
4 later decisions quote this exact passage · from the concurrence
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.