Savage v. Commissioner’s Empirical Analysis
1999
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 42 later decisions — most recently June 2018 · most notably Offiler v. Commissioner (2000), GAF Corp. v. Commissioner (2000)
4 federal appellate ·
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 Monge v. Commissioner · Normac, Inc. v. Commissioner · McCormick v. Commissioner · Judge v. Commissioner · Moretti v. Commissioner
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“to restrain or review any credit or reduction made by the Secretary [of the Treasury, i.e., the IRS] under section 6402.”
5 later decisions quote this exact passage“[A]fter applying an overpayment against the taxpayer's liability for another taxable year, the Commissioner is not precluded from subsequently determining a deficiency for the taxable year in respect of which the overpayment was originally claimed and allowed.”
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.