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← 85 TC 934 - Neely v. Commissioner

Neely v. Commissioner’s Empirical Analysis

1985

Citation profile

1,468
cited by 1,468 later decisions
June 2020
most recently cited

11 federal appellate ·

How this case has been cited

Cited by 1,468 later decisions — most recently June 2020 · most notably Niedringhaus v. Commissioner (1992), Rybak v. Commissioner (1988)

11 federal appellate ·

892019851990200020102020decided

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 Welch v. Helvering · Commissioner of Internal Revenue v. Duberstein D Stanton · Cohan v. Commissioner · United States v. Gilmore · Bixby v. Commissioner

Cited together with Welch v. Helvering · United States v. Boyle · New Colonial Ice Co. v. Helvering · Bixby v. Commissioner · Indopco, Inc. 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 1,468 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “lack of due care or failure to do what a reasonable and ordinarily prudent person would do under the circumstances.”
    23 later decisions quote this exact passage
  2. “substantial underpayment attributable to tax motivated transactions”
    23 later decisions quote this exact passage
  3. “if the value of any property, or the adjusted basis of any property, claimed on any return is 150 percent or more of the amount determined to be the correct amount of such valuation or adjusted basis.”
    7 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.