Freije v. Comm'r’s Empirical Analysis
2005
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 133 later decisions (1 by the Supreme Court) — most recently June 2025 · most notably Murphy v. Comm'r (2005), Hoyle v. Comm'r (2008)
1 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 Goza v. Commissioner · Montgomery v. Comm'r · Magana v. Comm'r · Landry v. Commissioner · Iannone 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 133 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[O]ur jurisdiction under section 6330(d)(1)(A) extends to the consideration of facts and issues in a nondetermination year only insofar as the tax liability for that year may affect the appropriateness of the collection action for the determination year.”
3 later decisions quote this exact passage“any relevant issue relating to the unpaid tax or the proposed levy”
3 later decisions quote this exact passage“[O]ur jurisdiction under section 6330(d)(1)(A) encompasses consideration of facts and issues in nondetermination years where the facts and issues are relevant in evaluating a claim that an unpaid tax has been paid.”
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.