Kaplan’s Empirical Analysis

Citation profile

3 district ·

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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “IRS policy has long permitted a taxpayer who 'voluntarily' submits a payment to the IRS to designate the tax liability to which the payment will apply. This policy reflects the generally recognized common law rule between debtors and creditors that the debtor may indicate which debt it intends to pay when it voluntarily submits a payment to a creditor, but may not dictate the application of funds that the creditor involuntarily collects from it.”

   1 later decision quote this exact passage · from the majority
   e.g. In re Goody's LLC

2. ““(1) the party to be estopped must have known the facts; (2) the party to be estopped must intend that his conduct will be acted upon or must so act that the party asserting the estoppel has the right to believe it was so intended; (3) the party asserting estoppel must be ignorant of the true facts; and (4) the party asserting estoppel must rely on the other party’s conduct to his injury.””

   1 later decision quote this exact passage · from the majority
   e.g. In Re American Appliance

3. “[A]ny payment made on the corporate account involved is deemed to represent payment of the employer portion of the liability * * * unless there was some specific designation to the contrary by the taxpayer.”

   1 later decision quote this exact passage · from the majority
   e.g. Dixon v. Commissioner