Matut v. Commissioner’s Empirical Analysis
1986
Citation profile
10
cited by 10 later decisions
September 1989
most recently cited
2 federal appellate ·
Relationships
Relies on Sunshine Anthracite Coal Co. v. Adkins · Commissioner v. Brown · Jacklin v. Commissioner · Bird v. United States · Espinoza 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Upon establishment of the identity of the true owner by us, respondent may, if so advised, abate the assessment previously made pursuant to section 6867(a) and (b) and replace it with an assessment against the person, firm, or corporation determined by us to be the true owner, as contemplated by subsection (c). In that circumstance, the proceedings would continue as though in the first instance the statutory notice had been issued to the true owner. But respondent cannot defeat the statutory remedy of the true owner by declining to replace the erroneous assessment and declining to issue a new statutory notice relating back to the date of the statutory notice issued pursuant to the presumption of section 6865(a) [6867(a)], * * * [ 86 T.C. at 691 .]”
1 later decision quote this exact passage“Matut I "). 3 7 The government moved for summary judgment on Matut's redetermination petition on the basis that the Tax Court did not have jurisdiction to determine the true owner of the cash. The Tax Court rejected this argument. It explained that "[the government's] primary contention would deprive both [Matut] and Lignarolo of any remedy in this court (and perhaps in any court), notwithstanding the direction and necessary implication in Sec. 6867(c) that once the true owner of cash is identified that person has the right to have the tax liability of the owner determined by us in this proceeding.”
1 later decision quote this exact passage“determine the identity of the 'true owner.'”
1 later decision 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.