Procacci v. Comm'r’s Empirical Analysis
1990
Citation profile
5
cited by 5 later decisions
July 2015
most recently cited
Relationships
Relies on Helvering v. National Grocery Co. · Freytag v. Commissioner · Federal Trade Commission v. Procter & Gamble Co. · Parker v. Commissioner · Achiro 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Achiro v. Commissioner , 77 T.C. 881 , 891 (1981) ; Boyer v. Commissioner , 58 T.C. 316 , 327 (1972) ; Ach v. Commissioner , 42 T.C. 114 , 126 (1964) , affd. 358 F.2d 342 (6th Cir. 1966) , cert. denied 385 U.S. 899 (1966) . If respondent does not indicate in the notice that he relies on sec. 482 , but so informs the taxpayer by pleadings far enough in advance of trial to avoid prejudice to the taxpayer, the burden is on respondent to establish all elements necessary to support this”
1 later decision quote this exact passage“the determination under section 482 is essentially and intensely factual”
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.