Fehlhaber v. Commissioner’s Empirical Analysis
1992
Citation profile
8 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 32 later decisions (1 by the Supreme Court) — most recently July 2017 · most notably Bufferd v. Commissioner (1993), Lardas v. Commissioner (1992)
8 federal appellate · 1 district · 1 state decisions
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. § 1363 · 26 U.S.C. § 1374 · 26 U.S.C. § 6012 · 26 U.S.C. § 6221 · 26 U.S.C. § 6229 · 26 U.S.C. § 6241 · 26 U.S.C. § 6501
Relies on Automobile Club of Mich. v. Commissioner · Ingraham v. Wright · Badaracco v. Commissioner · Peter J. Migliorini v. New York · Durovic 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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“for assessing any tax imposed under the Code.”
4 later decisions quote this exact passage“[a]ny return filed pursuant to [section 6037] shall, for purposes of chapter 66 (relating to limitations), be treated as a return filed by the corporation under section 6012.”
2 later decisions quote this exact passagee.g. Charles T. Green and Kay E. Green v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Gene C. Elkins and Louise Elkins v. Commissioner of Internal Revenue, R. Talley and Carolyn Melton v. Commissioner of Internal Revenue, Norman C. Way and Mary K. Way v. Commissioner of Internal Revenue, Bobby L. And Ramona A. Davis v. Commissioner of Internal Revenue, James R. And Elizabeth J. Graves v. Commissioner of Internal Revenue, Don C. And Audrey N. Quast v. Commissioner of Internal Revenue, Elizabeth C. Mayfield v. Commissioner of Internal Revenue, Jack E. And Jeanne Blanco v. Commissioner of Internal Revenue, Mike and Sandra Ann Kane v. Commissioner of Internal Revenue, Martin Brody and Jerrilyn Brody v. Commissioner of Internal Revenue · Green v. Commissioner“the limitations period for assessing a tax liability against a shareholder begins to run from the date that the individual, and not the S corporation, files his return.”
2 later decisions quote this exact passagee.g. Charles T. Green and Kay E. Green v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Robert White and Jean R. White v. Commissioner of Internal Revenue, Gene C. Elkins and Louise Elkins v. Commissioner of Internal Revenue, R. Talley and Carolyn Melton v. Commissioner of Internal Revenue, Norman C. Way and Mary K. Way v. Commissioner of Internal Revenue, Bobby L. And Ramona A. Davis v. Commissioner of Internal Revenue, James R. And Elizabeth J. Graves v. Commissioner of Internal Revenue, Don C. And Audrey N. Quast v. Commissioner of Internal Revenue, Elizabeth C. Mayfield v. Commissioner of Internal Revenue, Jack E. And Jeanne Blanco v. Commissioner of Internal Revenue, Mike and Sandra Ann Kane v. Commissioner of Internal Revenue, Martin Brody and Jerrilyn Brody v. Commissioner of Internal Revenue · Green 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.