7 canonical passages across 5 cases, quoted by 21 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 Reed v. Commissioner.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Reed v. Commissioner Anchor | green | “impermissibly expand the commissioner's authority by allowing him to evaluate an oic based on doubt as to collectibility using a taxpayer's past financial circumstances.” | 3 |
| 2 | Reed v. Commissioner | green | “it is fundamental that we have jurisdiction in collection matters if the commissioner issues a determination notice and a taxpayer timely files a petition.” | 3 |
| 3 | Reed v. Commissioner | green | “us to adopt the theory that respondent can be required” | 3 |
| 4 | Kendricks | green | “offer in compromise that was not before appeals.” | 3 |
| 5 | Cox | green | “has had no prior involvement in the determination and assessment of the underlying tax liability that is the subject of the hearing.” | 3 |
| 6 | Lewis | green | “more than just a rubber stamp for the commissioner's determinations,” | 3 |
| 7 | Thoburn v. Commissioner | green | “no other conceivable motive in submitting the offer” | 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.