3 canonical passages across 3 cases, quoted by 9 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 William Prentice Cooper, III v. Commissioner.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | William Prentice Cooper, III v. Commissioner Anchor | green | “because it did not occur in connection with a stand-alone request for interest abatement under section 6404 or because it was not made on a letter 3180, final determination letter for fully disallowing an interest abatement claim” | 3 |
| 2 | Swanson v. Commissioner | green | “acknowledges that the current state of the law is to use acquisition cost, adjusted for depreciation, rather than fair market value to compute net worth.” | 3 |
| 3 | Urbano v. Comm'r | green | “section 6404(h) authorizes the court to review for an abuse of discretion the commissioner's refusal to abate interest under section 6404.” | 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.