7 canonical passages across 5 cases, quoted by 29 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 Alexander v. Commissioner.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Alexander v. Commissioner Anchor | green | “transferee liability is several” | 5 |
| 2 | Stein v. Commissioner | green | “district courts have permitted equitable recoupment” | 4 |
| 3 | Stein v. Commissioner | green | “equitable recoupment is unavailable in cases to which section 1341 applies.” | 4 |
| 4 | Holmes v. Commissioner | green | “the tax liability of the transferor can be collected only once.” | 4 |
| 5 | Maynard Hospital, Inc. v. Commissioner | green | “equitable recoupment is unavailable in cases to which section 1341 applies.” | 4 |
| 6 | Maynard Hospital, Inc. v. Commissioner | green | “required to restore payments which he had received under a claim of right.” | 4 |
| 7 | Cappellini v. Commissioner | neutral | “the value of the assets distributed to the transferee substantially exceeds the transferor's aggregate liability for deficiencies, penalties, and interest, the transferee's liability for interest is governed by, and must be computed in accordance with, the internal revenue code.” | 4 |
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.