Princeton Univ. Press v. Michigan Document Servs., Inc., 74 F.3d 1528 (6th Cir. 1996). · Go Syfert
Princeton Univ. Press v. Michigan Document Servs., Inc., 74 F.3d 1528 (6th Cir. 1996). Cases Citing This Book View Copy Cite
91 citation events (69 in the last 25 years) across 10 distinct courts.
Strongest positive: Vikki L. Rogers, and Brian D. Rogers, Intervenor (tax, 2021-02-22)
Treatment trajectory · 1996 → 2026 · click a year to view as-of
1996 2011 2026
Top citers, strongest first. 31 distinct citers. How cited ↗
cited Cited as authority (rule) Vikki L. Rogers, and Brian D. Rogers, Intervenor
Tax Ct. · 2021 · confidence medium
Resser v. -9- [*9] Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996) (quoting Price v. Commissioner, 887 F.2d 959, 963 (9th Cir. 1989)), rev’g and remanding T.C.
discussed Cited as authority (rule) Dale Kleber v. CareFusion Corporation
7th Cir. · 2019 · confidence medium
As explained by Justice Thomas for a unanimous Supreme Court in Robinson v. Shell Oil, however, that observation does not prove that Congress chose not to provide that protection. 519 U.S. at 341– “the order denying him pauper status”); McMahon v. LVNV Funding, LLC, 807 F.3d 872, 875 (7th Cir. 2015) (observing that “the denial of class status is likely to be fatal to this litigation”); Moranski v. General Motors Corp., 433 F.3d 537, 538 (7th Cir. 2005) (analyzing “denial of Affinity Group status” affecting a proposed group of employees); Hileman v. Maze, 367 F.3d 694, 697 (7th Ci…
discussed Cited as authority (rule) Dale Kleber v. CareFusion Corporation
7th Cir. · 2019 · confidence medium
As explained by Justice Thomas for a unanimous Supreme Court in Robinson v. Shell Oil, however, that observation does not prove that Congress chose not to provide that protection. 519 U.S. at 341– “the order denying him pauper status”); McMahon v. LVNV Funding, LLC, 807 F.3d 872, 875 (7th Cir. 2015) (observing that “the denial of class status is likely to be fatal to this litigation”); Moranski v. General Motors Corp., 433 F.3d 537, 538 (7th Cir. 2005) (analyzing “denial of Affinity Group status” affecting a proposed group of employees); Hileman v. Maze, 367 F.3d 694, 697 (7th Ci…
discussed Cited as authority (rule) Dale Kleber v. CareFusion Corporation
7th Cir. · 2019 · confidence medium
As explained by Justice Thomas for a unanimous Supreme Court in Robinson v. Shell Oil, however, that observation does not prove that Congress chose not to provide that protection. 519 U.S. at 341– “the order denying him pauper status”); McMahon v. LVNV Funding, LLC, 807 F.3d 872, 875 (7th Cir. 2015) (observing that “the denial of class status is likely to be fatal to this litigation”); Moranski v. General Motors Corp., 433 F.3d 537, 538 (7th Cir. 2005) (analyzing “denial of Affinity Group status” affecting a proposed group of employees); Hileman v. Maze, 367 F.3d 694, 697 (7th Ci…
discussed Cited as authority (rule) Christopher Schorse, and Cynthia Palabrica, Intervenor v. Commissioner
Tax Ct. · 2018 · confidence medium
The U.S. Court of Appeals for the Seventh Circuit, to which this case is appealable absent an agreement between the parties, see sec. 7482(b), has adopted a more lenient approach in cases where the understatement results from improper deductions (versus cases involving unreported income), see Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996), rev’g and remanding T.C.
cited Cited as authority (rule) Rick E. Jacobsen v. Commissioner
Tax Ct. · 2018 · confidence medium
Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996), rev’g T.C.
discussed Cited as authority (rule) Dale Kleber v. CareFusion Corporation
7th Cir. · 2018 · confidence medium
Bell v. Kay, 847 F.3d 866, 868 (7th Cir. 2017) (plaintiff objected to “the order denying him pauper status”); McMahon v. LVNV Funding, LLC, 807 F.3d 872, 875 (7th Cir. 2015) (observing that “the denial of class status is likely to be fatal to this litigation”); Moranski v. General Motors Corp., 433 F.3d 537, 538 (7th Cir. 2005) (analyzing “denial of Affinity Group status” affecting a proposed group of employees); Hileman v. Maze, 367 F.3d 694, 697 (7th Cir. 2004) (plaintiff alleged injury resulting “from the denial of her status” as candidate in local election); Resser v. Comm�…
discussed Cited as authority (rule) Dale Kleber v. CareFusion Corporation
7th Cir. · 2018 · confidence medium
Bell v. Kay, 847 F.3d 866, 868 (7th Cir. 2017) (plaintiff objected to “the order denying him pauper status”); McMahon v. LVNV Funding, LLC, 807 F.3d 872, 875 (7th Cir. 2015) (observing that “the denial of class status is likely to be fatal to this litigation”); Moranski v. General Motors Corp., 433 F.3d 537, 538 (7th Cir. 2005) (analyzing “denial of Affinity Group status” affecting a proposed group of employees); Hileman v. Maze, 367 F.3d 694, 697 (7th Cir. 2004) (plaintiff alleged injury resulting “from the denial of her status” as candidate in local election); Resser v. Comm�…
cited Cited as authority (rule) John E. Rogers & Frances L. Rogers v. Commissioner
Tax Ct. · 2018 · confidence medium
Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996) (quoting Price v. Commissioner, 887 F.2d 959, 963 (9th Cir. 1989)), rev’g and remanding T.C.
cited Cited as authority (rule) Stephen D. Bowerman & Jani A. Bowerman v. Commissioner
Tax Ct. · 2014 · confidence medium
Memo. 1995-572 ; Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996), rev’g T.C.
examined Cited as authority (rule) Winnie Greer v. Comm'r of Internal Revenue (4×) also: Cited "see"
6th Cir. · 2010 · confidence medium
See Hayman v. Comm’r, 992 F.2d 1256, 1261 (2d Cir.1993); Reser v. Comm’r, 112 F.3d 1258, 1267 (5th Cir.1997); Resser v. Comm’r, 74 F.3d 1528, 1536 (7th Cir.1996); Erdahl v. Comm’r, 930 F.2d 585, 589 (8th Cir.1991); Kistner v. Comm’r, 18 F.3d 1521, 1527 (11th Cir.1994).
cited Cited as authority (rule) Construction and Design Compan v. USCIS
7th Cir. · 2009 · confidence medium
E.g., Resser v. Commissioner, 74 F.3d 1528, 1538 (7th Cir. 1996).
cited Cited as authority (rule) Construction & Design Co. v. United States Citizenship & Immigration Services
7th Cir. · 2009 · confidence medium
E.g., Resser v. Commissioner, 74 F.3d 1528, 1538 (7th Cir.1996).
discussed Cited as authority (rule) Rubin v. Tax Appeals Tribunal
N.Y. App. Div. · 2006 · confidence medium
Matter of Macaluso v New York State Dept. of Taxation & Fin., 259 AD2d 795, 796 [1999]; Resser v Commissioner of Internal Revenue, 74 F3d 1528, 1535 [1996]; Bliss v Commissioner of Internal Revenue, 59 F3d 374, 378 [1995]; Friedman v Commissioner of Internal Revenue, 53 F3d 523, 528-529 [1995] ; 4 Purcell v Commissioner of Internal Revenue, 826 F2d 470, 473 [1987], cert denied 485 US 987 [1988]) indicate that despite its liberal construction, one claiming an entitlement to its benefits must establish, by a preponderance of the evidence (see Friedman v Commissioner of Internal Revenue, supra at…
cited Cited as authority (rule) Alt v. Commissioner
6th Cir. · 2004 · confidence medium
“However, amounts received by a spouse in excess of normal support do constitute a significant benefit.” Resser v. Commissioner, 74 F.3d 1528, 1543 (7th Cir.1996) (citation omitted).
cited Cited as authority (rule) Mlay v. Internal Revenue Service
S.D. Ohio · 2001 · confidence medium
Id. (citing Resser v. Commissioner of Internal Revenue, 74 F.3d 1528, 1536 (7th Cir.1996)).
discussed Cited as authority (rule) In Re Hinckley
Bankr. M.D. Fla. · 2000 · confidence medium
See, e.g., Reser v. Comm'r of Internal Revenue, 112 F.3d 1258, 1267 (5th Cir.1997); Resser v. Comm'r of Internal Revenue, 74 F.3d 1528, 1535 (7th Cir.1996); Erdahl v. Comm’r of Internal Revenue, 930 F.2d 585, 589 (8th Cir.1991) (discussing knowledge of the underlying transaction that produced income as the standard in cases involving omission of income in contrast to cases involving deductions that give rise to an understatement of tax); Price v. Comm'r of Internal Revenue, 887 F.2d 959 , 963 at n. 9 (9th Cir.1989) (same); Purcell v. Comm’r of Internal Revenue, 826 F.2d 470, 474 (6th Cir.1…
discussed Cited as authority (rule) Rebecca Jo Reser v. Commissioner of Internal Revenue (2×) also: Cited "see"
5th Cir. · 1997 · confidence medium
See Park, 25 F.3d 1289, 1292 (1994). 46 .See Price, 887 F.2d at 965 ; Stevens v. Commissioner, 872 F.2d 1499, 1505 (11th Cir.1989); Erdahl v. Commissioner, 930 F.2d 585, 590-91 (8th Cir.1991); Friedman, 53 F.3d at 531 ; Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996); Bliss v. Commissioner, 59 F.3d 374, 378 (2d Cir.1995). 47 .
discussed Cited as authority (rule) LaSalle Bank Lake View v. Seguban
N.D. Ill. · 1996 · confidence medium
The court notes that “the more a spouse knows about a transaction, ceteris paribus, the more likely it is that [he] will know or have reason to know that the deduction arising from that transaction may not be valid.” Resser v. C.I.R., 74 F.3d 1528, 1536 (7th Cir.1996) (citation omitted).
cited Cited as authority (rule) In re Lesnick
Bankr. N.D. Ohio · 1996 · confidence medium
Resser v. Commissioner, 74 F.3d 1528, 1542 (7th Cir.1996) (citations omitted).
discussed Cited as authority (rule) REBECCA JO RESER v. COMMISSIONER OF INTERNAL REVENUE (2×)
unknown court · confidence medium
They have concluded instead that the proper inquiry is whether the spouse seeking relief knew or had reason to know that the deduction would give rise to a substantial understatement.33 The leading case in this camp is the Ninth Circuit’s decision in Price v. Commissioner.34 The Tax Court, however, in Bokum v. Commissioner,35 explicitly refused to acquiesce in Price and continues to apply the knowledge-of-the-transaction test in omission of income cases and erroneous deduction cases alike.36 In Bokum, the Tax Court found support for 33 See Bliss v. Commissioner, 59 F.3d 374 , 378 n.1 (2d Cir…
cited Cited "see" Joanne Salvi Vanover, and Michael D. Vanover, Intervenor
Tax Ct. · 2025 · signal: see · confidence high
See Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996), rev’g and remanding T.C.
cited Cited "see" Kari Jane Freman, and Rodney C. Freman, Intervenor
Tax Ct. · 2023 · signal: see · confidence high
See Resser v. Commissioner, 74 F.3d 1528, 1536 (7th Cir. 1996), rev’g and remanding T.C.
examined Cited "see" Frances Rogers v. CIR (3×)
7th Cir. · 2021 · signal: see · confidence high
See Resser, 74 F.3d at 1535 .
discussed Cited "see" Cheshire v. CIR
5th Cir. · 2002 · signal: see · confidence high
See Resser v. Comm’r, 74 F.3d 1528, 1535-36 (7th Cir. 1996); Bliss v. Comm’r, 59 F.3d 374 , 378 n.1 (2d Cir. 1995); Kistner v. Comm’r, 18 F.3d 1521, 1527 (11th Cir. 1994); Erdahl v. Comm’r, 930 F.2d 585, 589 (8th Cir. 1991). 13 In this case, the Cheshires reported the receipt of $199,771.05 in retirement distributions on line 17a of their joint tax return.
discussed Cited "see" Kathryn Cheshire v. Commissioner of Internal Revenue
5th Cir. · 2002 · signal: see · confidence high
See Resser v. Comm’r, 74 F.3d 1528, 1535-36 (7th Cir.1996); Bliss v. Comm’r, 59 F.3d 374 , 378 n. 1 *334 (2d Cir.1995); Kistner v. Comm’r, 18 F.3d 1521, 1527 (11th Cir.1994); Erdahl v. Comm’r, 930 F.2d 585, 589 (8th Cir.1991). 19 .
cited Cited "see" Phemister
unknown court · L. · signal: see · confidence high
See Resser v. Commissioner , 74 F.3d 1528 , 1535-1536 (7th Cir. 1996) , *240 revg. and remanding T.C.
discussed Cited "see, e.g." Rick Jacobsen v. CIR
7th Cir. · 2020 · signal: see, e.g. · confidence medium
II The Internal Revenue Code specifies that a husband and wife who file a joint tax return are jointly and severally liable for the taxes on their combined incomes. 26 U.S.C. § 6013 (d); see, e.g., Resser v. C.I.R., 74 F.3d 1528, 1534 (7th Cir. 1996).
discussed Cited "see, e.g." Rick Jacobsen v. CIR
7th Cir. · 2020 · signal: see, e.g. · confidence medium
II The Internal Revenue Code specifies that a husband and wife who file a joint tax return are jointly and severally liable for the taxes on their combined incomes. 26 U.S.C. § 6013 (d); see, e.g., Resser v. C.I.R., 74 F.3d 1528, 1534 (7th Cir. 1996).
discussed Cited "see, e.g." Rick Jacobsen v. CIR
7th Cir. · 2020 · signal: see, e.g. · confidence medium
II The Internal Revenue Code specifies that a husband and wife who file a joint tax return are jointly and severally liable for the taxes on their combined incomes. 26 U.S.C. § 6013 (d); see, e.g., Resser v. C.I.R., 74 F.3d 1528, 1534 (7th Cir. 1996).
cited Cited "see, e.g." Meyer v. Commissioner
Tax Ct. · 1996 · signal: compare · confidence low
Compare Resser v. Commissioner , 74 F.3d 1528 , 1540 (7th Cir. 1996) , revg.
Retrieving the full opinion text from the archive…
PRINCETON UNIVERSITY PRESS, ET AL., Plaintiffs-Appellees,
v.
MICHIGAN DOCUMENT SERVICES, INC., ET AL., Defendants-Appellants
94-1778.
Court of Appeals for the Sixth Circuit.
Apr 9, 1996.
74 F.3d 1528
Merritt, Kennedy, Martin, Milburn, Nelson, Ryan, Boggs, Norris, Suhrheinrich, Siler, Batchelder, Daughtrey, Moore, Cole.
Published

ORDER

A majority of the Judges of this Court in regular active service have voted for rehearing of this case en banc. Sixth Circuit Rule 14 provides as follows:

The effect of the granting of a hearing en banc shall be to vacate the previous opinion and judgment of this court, to stay the mandate and to restore the case on the docket sheet as a pending appeal.

Accordingly, it is ORDERED that the previous decision and judgment of this court is vacated, the mandate is stayed and this case is restored to the docket as a pending appeal.

The Clerk will direct the parties to file supplemental briefs and will schedule this case for oral argument as soon as possible.