Matut v. Commissioner’s Empirical Analysis
1985
Citation profile
8
cited by 8 later decisions
June 1992
most recently cited
2 federal appellate ·
Relationships
Relies on Sampson v. Commissioner · Cincinnati Transit, Inc. v. Commissioner · Cincinnati Transit, Inc. v. Commissioner · Guarino v. Commissioner · Estate of Siegel v. Commissioner
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General Rule. — If the individual who is in physical possession of cash in excess of $10,000 does not claim such cash— (1) as his, or (2) as belonging to another person whose identity the Secretary can readily ascertain and who acknowledges ownership of such cash, then, for purposes of sections 6851 and 6861, it shall be presumed that such cash represents gross income of a single individual for the taxable year in which the possession occurs, and that the collection of tax will be jeopardized by delay. (b) Rules for Assessing. — In the case of any assessment resulting from the application of subsection (al- ii) the entire amount of the cash shall be treated as taxable income for the taxable year in which the possession occurs, (2) such income shall be treated as taxable at a 50-percent rate, and (3) except as provided in subsection (c), the possessor of the cash shall be treated (solely with respect to such cash) as the taxpayer for purposes of chapters 63 and 64 and section 7429(a)(1). (c) Effect of Later Substitution of True Owner. — If, after an assessment resulting from the application of subsection (a), such assessment is abated and replaced by an assessment against the owner of the cash, such later assessment shall be treated for purposes of all laws relating to lien, levy and collection as relating back to the date of the original assessment.”
1 later decision quote this exact passage“Congress never intended that the possessor of the cash be brought into this Court in his individual capacity.”
1 later decision quote this exact passagee.g. Ono v. Commissioner
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.