Diane S. Blodgett v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that waiver eliminates “any right to appellate plain error review”
• finding in the context of proving tax loss, which is entitled to a presumption of correctness, that “we review de novo the legal question of whether a taxpayer produced sufficient evidence to shift the burden of proof”
• indicating that stipulation constitutes waiver
• party supported by weight of evidence will prevail regardless of who bore burden of proof
• \[A] shift in the burden of preponderance has real significance only in the rare event of an evidentiary tie.\
• “[A] shift in the burden of preponderance has real significance only in the rare event of an evidentiary tie.”

Source: CourtListener parenthetical corpus (CC0).