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← 91 TC 1019 - Abeles v. Commissioner

Abeles v. Commissioner’s Empirical Analysis

1988

Citation profile

161
cited by 161 later decisions
August 2019
most recently cited

5 federal appellate ·

How this case has been cited

Cited by 161 later decisions — most recently August 2019 · most notably Monge v. Commissioner (1989), Orum v. Comm'r (2004)

5 federal appellate ·

8801988199020002010decided

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 United States v. American Trucking Associations · Golsen v. Commissioner · Golsen v. Commissioner · Takao Ozawa v. United States · Cool Fuel, Inc. v. Connett

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

  1. “a taxpayer's last known address is that address which appears on the taxpayer's most recently filed return, unless respondent has been given clear and concise notification of a different address.”
    5 later decisions quote this exact passage
  2. “"Further, we hold that the address from the more recently filed return is available to the agent issuing a notice of deficiency ... if such address could be obtained by a computer generation of an IRS computer transcript using the taxpayer’s TIN_’’ (emphasis in original).”
    4 later decisions quote this exact passage
  3. “'to * * * [the Commissioner] information which * * * [the Commissioner] knows, or should know, with respect to a taxpayer's last known address, through the use of its computer system.'”
    3 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.