Risman v. Commissioner’s Empirical Analysis
1993
Citation profile
7 federal appellate · 4 district ·
How this case has been cited
Cited by 29 later decisions — most recently April 2023 · most notably Gabelman v. Commissioner of Internal Revenue (1996), Ott v. United States (1998)
7 federal appellate · 4 district ·
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Rosenman v. United States · Crocker v. Commissioner · Ewing v. United States · Fortugno v. Commissioner · Weiss v. Temporary Investment Fund, Inc.
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]n light of our conclusion that remittances made by taxpayers with Form 4868 extension requests are not necessarily to be treated, as a matter of law, as payments of tax as of the filing date of the associated income tax return and based on the facts and circumstances of this case, petitioners’ April 15, 1982, $25,000 remittance is to be treated as a deposit and not as a payment of taxes.”
3 later decisions quote this exact passage“A remittance by a taxpayer to respondent generally will not be regarded as a payment of Federal income tax until the taxpayer intends that the remittance satisfy what the taxpayer regards as an existing tax liability.”
2 later decisions quote this exact passage“Such application for extension must show the full amount properly estimated as tax for such taxpayer for such taxable year . . . .”
2 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.