Barton v. Commissioner’s Empirical Analysis
1991
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 41 later decisions — most recently February 2011 · most notably Zfass v. Commissioner (1997), Pen Coal Corp. v. Commissioner (1996)
6 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 Naftel v. Commissioner · Judge v. Commissioner · Estate of Young v. Commissioner · White v. Commissioner · Estate of Baumgardner 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]dditional interest [under section 6621(c)] is the `interest' prescribed under section 6601, with the rate of interest increased to 120 percent of the underpayment rate . . ., additional interest [under section 6621(c)] is not a `deficiency' within the meaning of section 6211(a).”
1 later decision quote this exact passage“this Court does not have jurisdiction under section 6621(c)(4) in the setting presented in this case to determine whether additional interest applies because the deficiency before the Court is not a substantial underpayment attributable to tax-motivated transactions.”
1 later decision quote this exact passage“[S]ection 6601(e)(1) specifically excludes interest [including section 6621(c) interest] from being treated as `tax' in deficiency proceedings.”
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.