Fredericks v. Commissioner’s Empirical Analysis
1997
Citation profile
14 federal appellate · 4 district · 1 state decisions
How this case has been cited
Cited by 38 later decisions — most recently December 2018 · most notably Tefel v. Reno (1999), ACM Partnership v. Commissioner (1998)
14 federal appellate · 4 district · 1 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. § 6601 · 26 U.S.C. § 6621
Relies on Federal Crop Ins Corporation v. Merrill · Heckler v. Community Health Services of Crawford County, Inc. · Office of Personnel Management v. Richmond · Schweiker v. Hansen · Stearns Co of Boston Mass v. United States
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although the Supreme Court has neither rejected outright nor articulated a specific test for estoppel claims against the government, the foregoing case law illuminates certain factors beyond the traditional elements of estoppel that we should consider before estopping the IRS. Those factors are: 1) the impact of the estoppel on the public fisc; 2) whether the government agent or agents who made the misrepresentation or error were authorized to act as they did; 3) whether the governmental misconduct involved a question of law or fact; 4) whether the government benefitted from its misrepresentation; and 5) the existence of irreversible detrimental reliance by the party claiming estoppel.”
1 later decision quote this exact passage · from the majority“The IRS' decision to lie doggo, and induce the taxpayer into thinking all was well, coupled with its additional eight-year delay in producing a document it previously represented as non-existent, compels us to conclude that the IRS was guilty of affirmative misconduct....”
1 later decision quote this exact passage · from the majority“[A] private party's reliance on governmental actions or omissions is not reasonable if such acts or omissions are contrary to the law”
1 later decision 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.