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← 92 TC 363 - Seneca, Ltd. v. Commissioner

Seneca, Ltd. v. Commissioner’s Empirical Analysis

1989

Citation profile

23
cited by 23 later decisions
1
states following
February 2016
most recently cited

3 federal appellate · 1 state decisions

How this case has been cited

Cited by 23 later decisions — most recently February 2016

3 federal appellate · 1 state decisions

1801989199020002010decided

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

Applies 26 U.S.C. § 6223

Relies on Computer Programs Lambda, Ltd. v. Commissioner · Clovis I v. Commissioner · Chomp Assoc. v. Commissioner · Computer Programs Lambda, Ltd. v. Commissioner · Transpac Drilling Venture 1982-22 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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[any injury that petitioners suffer as a result of filing their petition out of time was caused by their own inaction and was not caused by respondent's conduct.”
    1 later decision quote this exact passage
  2. “the absence of a tax matters partner for Seneca had no adverse effect on petitioners' rights to notice and hearing.”
    1 later decision quote this exact passage
  3. “Notice of Final Partnership Administrative Adjustment”
    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.