Karr v. Commissioner’s Empirical Analysis
1991
Citation profile
35 federal appellate · 1 district ·
How this case has been cited
Cited by 94 later decisions — most recently July 2016 · most notably ACM Partnership v. Commissioner (1998), Krause v. Commissioner (1992)
35 federal appellate · 1 district ·
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. § 174 · 26 U.S.C. § 6621
Relies on Knetsch v. United States · Brannen v. Commissioner · Rice's Toyota World, Inc. v. Commissioner · Beck v. Commissioner · Rose 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 94 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“arbitrarily, capriciously, or without sound basis in fact.”
5 later decisions quote this exact passage · from the majority“[t]he Secretary may waive all or part of the addition to tax provided by [the substantial understatement of liability] section on a showing by the taxpayer that there was reasonable cause for the understatement (or part thereof) and that the taxpayer acted in good faith.”
2 later decisions quote this exact passage · from the majority“an examination of the substance of the transactions to determine whether those transactions had any practicable economic effect other than the creation of tax benefits.”
2 later decisions quote this exact passage · from the majority
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.