Thomas C. Harrison and Rita Harrison v. Commissioner of Internal Revenue (1988)
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· 70 citation events
across 9 courts.
Showing the 28 strongest citers on record
(one row per citing case, strongest signal kept).
Treatment trajectory · 1988 → 2026 · click a year to view the case as of then
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Paul Johnson v. CIR (2020)
Because the Johnsons failed to provide “any documents, records, or other objective evidence” supporting that they had properly rolled over their IRA, the Tax Court reasoned that “the Commissioner [wa]s not required to concede the adjustments until he [ ] received and had reasonable time to 5 The IRS informed the Johnsons that it was unable to send copies of the documents that they had requested, because the IRS had received the information electronically. 7 Case: 20-60054 Do…
“The IRS took the position of conceding the case as soon as it received and verified information demonstrating that that was the proper course. This was a reasonable position.”
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RICHARDSON. v. COMMISSIONER (1998)
Harrison v. Commissioner, 854 F.2d 263, 265 (7th Cir. 1988), affg.
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In Re Chambers (1992)
The court noted that Ms. Chambers had the burden of proving that the government’s position was not substantially justified, Harrison v. C.I.R., 854 F.2d 263, 265 (7th Cir.1988), and that the fact that the government lost in the underlying litigation did not mean that its position was unreasonable.
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In Re Chambers (1991)
Harrison v. C.I.R., 854 F.2d 263, 265 (7th Cir.1988).
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John C. Zinniel v. Commissioner Of Internal Revenue (1989)
See Harrison v. Commissioner, 854 F.2d at 265 .
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Zinniel v. Commissioner (1989)
See Harrison v. Commissioner, 854 F.2d at 265 .
See Harrison v. Commissioner of Internal Revenue, 854 F.2d 263, 265 (7th Cir.1988) (“The IRS took the position of conceding the case as soon as it received and verified information demonstrating that that was the proper course”).
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Price v. Commissioner (1994)
Powers v. Commissioner , 100 T.C. 457 , 471 (1993) ; see also Harrison v. Commissioner , 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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Smith v. United States (1990)
See Harrison v. Commissioner of Internal Revenue, 854 F.2d 263 , 265 n. 3 (7th Cir.1988), cert. denied, — U.S. —, 109 S.Ct. 1313 , 103 L.Ed.2d 582 (1989).
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Sokol v. Commissioner (1989)
See and compare Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) , affg. a Memorandum Opinion of this Court (concession some 6 months after answer filed, after respondent had an opportunity to verify information, held reasonable); Ashburn v. United States , 740 F.2d 843 (11th Cir. 1984) (11-month delay in conceding case not unreasonable); Wickert v. Commissioner , 842 F.2d 1005 (8th Cir. 1988) , affg. a Memorandum Opinion of this Court (concession 10 days after filing…
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O'Bryon v. Commissioner (2000)
See Harrison v. Commissioner, 854 F.2d 263 (7th Cir. 1988) (concession some 6 months after the answer was filed, after the Government had an opportunity to verify information, held reasonable), affg.
concession some 6 months after the answer was filed, after the Government had an opportunity to verify information, held reasonable
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Sik v. Commissioner (1999)
See Harrison v. Commissioner, 854 F.2d 263 , 266 (7th Cir. 1988) , affg.
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Tandon v. Commissioner (1998)
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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Brantley v. Commissioner (1995)
See, e.g., Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) (concession approximately 6 months after answer filed, after respondent had an opportunity to verify information, held reasonable), affg.
concession approximately 6 months after answer filed, after respondent had an opportunity to verify information, held reasonable
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Morrow v. Commissioner (1995)
See, e.g., Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) (concession approximately 6 months after answer filed, after respondent had an opportunity to verify information, held reasonable), affg.
concession approximately 6 months after answer filed, after respondent had an opportunity to verify information, held reasonable
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Renner v. Commissioner (1994)
See, e.g., Harrison v. Commissioner , 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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Abernathy v. United States (In Re Abernathy) (1993)
See Harrison v. C.I.R., 854 F.2d 263, 265 (7th Cir.1988).
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Estate of Dooley v. Commissioner (1992)
See and compare Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) , affg.
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Lennox v. Commissioner (1992)
See Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) , affg.
See Harrison v. C.I.R., 854 F.2d 263 , 265 n. 3 (7th Cir.1988), cert. denied, 489 U.S. 1053 , 109 S.Ct. 1313 , 103 L.Ed.2d 582 (1989) (noting split in authorities, but not taking position).
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Creske v. Commissioner (1990)
Compare Harrison v. Commissioner , 854 F.2d 263 (7th Cir. 1988) , affirming T.C.
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Brown v. Commissioner (1989)
See and compare Harrison v. Commissioner, 854 F.2d 263 (7th Cir. 1988) , affg. a *160 Memorandum Opinion of this Court; Ashburn v. United States, 740 F.2d 843 (11th Cir. 1984) ; Wickert v. Commissioner, 842 F.2d 1005 (8th Cir. 1988) , affg. a Memorandum Opinion of this Court; White v. United States, 740 F.2d 836 , 842 (11th Cir. 1984) . 9 That almost eight months apparently elapsed between the filing of the answer and Mrs. Ayer's suggestion of filing affidavits does not make…
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Calitri
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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McIntosh
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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ROLING
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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Prouty
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.
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Blasius
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) (Government's conduct considered "reasonable" where, after being advised that the partnership in which the taxpayer was a limited partner had received a "no-change" letter, the Government's counsel conceded the case "within a month" during which time counsel "verified information demonstrating that that was the proper course"), affg.
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Hennessey
See Harrison v. Commissioner, 854 F.2d 263 , 265 (7th Cir. 1988) , affg.