Murphy v. Comm'r’s Empirical Analysis
2005
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 457 later decisions — most recently October 2020 · most notably Thompson v. Commissioner (2013), Kindred v. Commissioner (2006)
2 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
Applies 26 U.S.C. § 6330
Relies on Citizens to Preserve Overton Park, Inc. v. Volpe · Califano v. Sanders · Florida Power & Light Co. v. Lorion · Goza v. Commissioner · United States v. Carlo Bianchi & 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 457 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[E]vidence that * * * [a taxpayer] might have presented at the section 6330 hearing (but chose not to) is not admissible in a trial conducted pursuant to section 6330(d)(1) because it is not relevant to the question of whether the Appeals officer abused her discretion.”
7 later decisions quote this exact passage · from the concurrencee.g. Clayton v. Comm'r · Smith v. Comm'r“attempt to conduct a * * * [section 6330 ] hearing and issue a Notice of Determination as expeditiously as possible under the circumstances.”
5 later decisions quote this exact passage · from the concurrencee.g. Shanley v. Comm'r · Jones v. Comm'r“raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy”
5 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.