Sego v. Commissioner’s Empirical Analysis
2000
Citation profile
3 federal appellate · 7 district ·
How this case has been cited
Cited by 1,173 later decisions (1 by the Supreme Court) — most recently June 2025 · most notably Giamelli v. Comm'r (2007), Katz v. Commissioner (2000)
3 federal appellate · 7 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 Goza v. Commissioner · United States v. Zolla · Owens v. Davis · United States v. Ahrens · Pietanza v. Commissioner
Cited together with Goza v. Commissioner · Sundstrand Corp. v. Commissioner · Sundstrand Corp. v. Commissioner · Woodral v. Commissioner · Murphy v. Comm'r
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 1,173 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“did not receive any statutory notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability.”
81 later decisions quote this exact passage“whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the person that any collection action be no more intrusive than necessary.”
40 later decisions quote this exact passagee.g. Orian v. Comm'r · McGowan v. Comm'r“In a collection due process case in which the underlying tax liability is properly at issue, the Tax Court (and hence this Court) reviews the underlying liability de novo and reviews the other administrative determinations for an abuse of discretion.”
5 later decisions quote this exact passagee.g. Estate v. Comm'r · Dalton v. Comm'r
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.