Chai v. Commissioner’s Empirical Analysis

851 F.3d 190 · 2017

Citation profile

109

cited by 109 later decisions

September 2022

most recently cited

9 federal appellate ·

Relationships

Applies 26 U.S.C. § 1231 · 26 U.S.C. § 1401 · 26 U.S.C. § 1402 · 26 U.S.C. § 162 · 26 U.S.C. § 183 · 26 U.S.C. § 475 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6201

Relies on Skidmore v. Swift & Co. · Singleton v. Wulff · Coopers & Lybrand v. Livesay · Catlin v. United States · Hormel v. Helvering

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 109 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“no later than the date the IRS issues the notice of deficiency (or files an answer or amended answer) asserting such penalty.”
7 later decisions quote this exact passage · from the dissent
e.g. Partners v. Comm'r · PBBM-Rose Hill, Ltd. v. Comm'r of Internal Revenue
“initial determination of such assessment”
4 later decisions quote this exact passage · from the dissent
e.g. Partners v. Comm'r · Roth v. C.I.R.
“[p]artnership tax [wa]s subject to the procedures set forth in the Tax Equity and Fiscal Responsibility Act of 1982 ('TEFRA'), Pub. L. No. 97-248, 96 Stat. 324 (codified as amended at I.R.C. §§ 6221 - 6234 ).”
2 later decisions quote this exact passage · from the majority
e.g. Omega Forex Grp., LC v. United States · Capitol BC Restaurants, LLC v. Commissioner (In re Capitol BC Restaurants, LLC)

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.