Monge v. Commissioner’s Empirical Analysis
1989
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 239 later decisions — most recently August 2020 · most notably Offiler v. Commissioner (2000), Ewing v. Commissioner (2002)
4 federal appellate ·
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 Golsen v. Commissioner · Golsen v. Commissioner · Cool Fuel, Inc. v. Connett · Bradshaw v. Sea World, Inc · Frieling 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 239 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A]fter respondent becomes aware of a taxpayer's change of address, he must exercise reasonable care and diligence in ascertaining and mailing the notice of deficiency to the correct address.”
2 later decisions quote this exact passage“is the address to which, in light of all surrounding facts and circumstances, respondent reasonably believed the taxpayer wished the notice of deficiency to be sent. E.g., United States v. Ahrens, 530 F.2d 781 , 785 (8th Cir. 1976) ; Looper v. Commissioner, 73 T.C. 690 , 696 (1980) . Until recently, it has been our position that respondent is entitled to treat the address of the taxpayer appearing on the return under examination as the taxpayer's last known address, absent”
1 later decision quote this exact passage“that return which has been properly processed by an IRS service center such that the address appearing on such return was available to respondent's agent when that agent prepared to send a notice of deficiency in connection with an examination of a previously filed return.”
1 later decision quote this exact passagee.g. Hawk v. Commissioner
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.