Legal Opinion

Summa Holdings v. Comm'r of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided February 16, 2017No. 16-1712PublishedCited by 17 opinions

1Opinion of the Court

OPINION

SUTTON, Circuit Judge.

Caligula posted the tax laws in such fine print and so high that his subjects could not read them. Suetonius, The Twelve Caesars, bk. 4, para. 41 (Robert Graves, trans., 1957). That’s not a good idea, we can all agree. How can citizens comply with what they can’t see? And how can anyone assess the tax collector’s exercise of power in that setting? The Internal Revenue Code improves matters in one sense, as it is accessible to everyone with the time and patience to pore over its provisions.

In today’s case, however, the Commissioner of the Internal Revenue Service…

2Cases cited18 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  3. Knetsch v. United StatesSupreme Court of the United States · 1960
  4. Towne v. EisnerSupreme Court of the United States · 1918
  5. Minnesota Tea Co. v. HelveringSupreme Court of the United States · 1938

13 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Lynwood Pickens v. Hamilton-Ryker IT SolutionsCourt of Appeals for the Sixth Circuit · 2025
  2. Benenson v. Comm'r of Internal RevenueCourt of Appeals for the First Circuit · 2018
  3. Billy F. Hawk, Jr., GST Non-Exempt Marital Trust v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2019
  4. Benenson v. Comm'rCourt of Appeals for the Second Circuit · 2018
  5. Celia Mazzei v. CommissionerUnited States Tax Court · 2018

12 more not listed; retrieve them via the Exa API.

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