Cavallaro v. Commissioner’s Empirical Analysis
842 F.3d 16 · 2016
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 6651 · 26 U.S.C. § 6662 · 26 U.S.C. § 7482 · 26 U.S.C. § 7491
Relies on Anderson v. City of Bessemer City · Helvering v. Taylor · United States v. Janis · Commissioner of Internal Revenue v. Culbertson · Bull v. United States
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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he taxpayer typically bears the burden of proving by a preponderance of the evidence that the Commissioner's tax assessment is erroneous.”
2 later decisions quote this exact passage“[C]ourts commonly find [that a deficiency lacks a rational foundation] when the Commissioner makes no evidentiary showing at all.”
2 later decisions 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.