7 canonical passages across 5 cases, quoted by 23 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 Mayrath v. Commissioner.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Mayrath v. Commissioner Anchor | green | “whether an uncertainty exists is an objective test that depends on the information available to the taxpayer.” | 5 |
| 2 | Shami v. Commissioner | green | “the cohan rule is not implicated unless the taxpayer proves that he is entitled to some amount of tax ben- efit.” | 3 |
| 3 | Suder v. Comm'r | green | “satisfy the re- quirements of section 41(d)(1)(a)” | 3 |
| 4 | Comm'r | green | “add a few new bells and whistles” | 3 |
| 5 | Comm'r | green | “an analytical technique by which a hypothesis is formulated and then systematically tested through observation and experimentation.” | 3 |
| 6 | Comm'r | green | “deductions under section 174 are limited to 'expenditures of an investigative nature expended in devel- oping the concept of a model or product,' as opposed to the construction or manufacture of the product itself.” | 3 |
| 7 | Norwest Corp. v. Comm'r | green | “test also imposes a more structured method of discovering infor- mation than section 174 requires and may not include all ac- tions a taxpayer takes to resolve uncertainty.” | 3 |
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.