2 canonical passages across 2 cases, quoted by 30 opinions in total. These passages cluster together because the same opinions keep quoting them side by side — they state parts of one doctrine. The anchor passage is from HIGBEE.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | HIGBEE Anchor | green | “if, in any court proceeding, a taxpayer introduces credible evidence with respect to any factual issue relevant to ascertaining the liability of the taxpayer for any tax imposed by subtitle a or b, the secretary shall have the burden of proof with respect to such issue.” | 18 |
| 2 | Herald A. O'Neill and G. Evelyn O'neill, His Wife v. Commissioner of Internal Revenue | green | “proof of basis is a specific fact which the taxpayer has the burden of proving.” | 12 |
A red or yellow flag on a member means the underlying case has negative treatment — for those, check the case page before relying on the passage.