Tax Analysts v. Internal Revenue Service’s Empirical Analysis
117 F.3d 607 · 1997
Citation profile
52 federal appellate · 187 district · 3 state decisions
How this case has been cited
Cited by 329 later decisions — most recently July 2024 · most notably County of Los Angeles v. Shalala (1999), Donald Rehling v. The City of Chicago, a Municipal Corporation (2000)
52 federal appellate · 187 district · 3 state decisions
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
Applies 26 U.S.C. § 6103 · 26 U.S.C. § 6108 · 26 U.S.C. § 6110 · 26 U.S.C. § 6653 · 26 U.S.C. § 6658 · 31 U.S.C. § 301 · 5 U.S.C. § 552 (Freedom of Information Act) · 5 U.S.C. § 553 (Administrative Procedure Act of 1946)
Relies on Miranda v. State of Arizona Vignera · Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Hickman v. Taylor · Auer v. Robbins · National Labor Relations Board v. Sears, Roebuck & Co.
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 329 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a taxpayer’s identity, the nature, source, or amount of his income, payments, receipts, deductions, exemptions, credits, assets, liabilities, net worth, tax liability, tax withheld, deficiencies, overassess-ments, or tax payments, whether the taxpayer’s return was, is being, or will be examined or subject to other investigation or processing, or any other data, received by, recorded by, prepared by, furnished to, or collected by the Secretary with respect to a return or with respect to the determination of the existence, or possible existence, of liability (or the amount thereof) of any person under this title for any tax, penalty, interest, fine, forfeiture, or other imposition, or offense....”
17 later decisions quote this exact passage · from the majority“In the governmental context, the 'client' may be the agency and the attorney may be an agency lawyer.”
13 later decisions quote this exact passage · from the majority“A document is predecisional if it was prepared in order to assist an agency decisionmaker in arriving at his decision, rather than to support a decision already made. Material is deliberative if it reflects the give-and-take of the consultative process. [The D.C. Circuit’s] recent decisions on the deliberativeness inquiry have focused on whether disclosure of the requested material would tend to discourage candid discussion within an agency.”
6 later decisions quote this exact passage · from the majority
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.