Pearce v. Commissioner’s Empirical Analysis
1990
Citation profile
5
cited by 5 later decisions
August 2020
most recently cited
Relationships
Relies on Howard S. Scar and Ethel M. Scar v. Commissioner of Internal Revenue · Clapp v. Commissioner · Roat v. Commissioner · Scar v. Commissioner · Hannan 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.
“In Scar, there was never a question whether a return had been filed. It was clear from the face of the notice of deficiency that a return had been filed and was being ignored for reasons of administrative expediency.”
1 later decision quote this exact passage“conclude[d] that the Commissioner must consider information that relates to a particular taxpayer before it can be said that the Commissioner has 'determined' a 'deficiency' in respect to that taxpayer.”
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.