Hayman v. Commissioner’s Empirical Analysis
1993
Citation profile
20 federal appellate · 2 district ·
How this case has been cited
Cited by 143 later decisions — most recently March 2021 · most notably 101 F. App'x 34 - Alt v. Commissioner (2004), Jonson v. Comm'r (2002)
20 federal appellate · 2 district ·
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. § 6013 · 26 U.S.C. § 6621
Relies on Director, Office of Workers' Compensation Programs v. Broyles · Honig v. Doe · In re Disbarment of Goldman · United Savings Ass'n of Texas v. Timbers of Inwood Forest Associates, Inc. · Purcell 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 143 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Tax returns setting forth large deductions, such as tax shelter losses offsetting income from other sources and substantially reducing or eliminating the couple's tax liability, generally put a taxpayer on notice that there may be an understatement of tax liability.”
11 later decisions quote this exact passage · from the majoritye.g. Albin v. Comm'r · Barnes v. Comm'r“she [or he] did not know and did not have reason to know that the deduction would give rise to a substantial understatement.”
8 later decisions quote this exact passage · from the majority“a reasonably prudent taxpayer in her position at the time she signed the return could be expected to know that the return contained the substantial understatement.”
6 later decisions quote this exact passage · from the majority
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.