Singleton v. United States’s Empirical Analysis
128 F.3d 833 · 1997
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 19 later decisions — most recently July 2016
7 federal appellate · 1 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
Applies 26 U.S.C. § 38 · 26 U.S.C. § 6201 · 26 U.S.C. § 6204 · 26 U.S.C. § 6211 · 26 U.S.C. § 6213 · 26 U.S.C. § 6303 · 26 U.S.C. § 6501 · 26 U.S.C. § 6532
Relies on O'Bryant v. United States · United States v. Wilkes · Clark III v. United States · Bilzerian v. USA
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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Tax Code does not prohibit supplemental assessments without notice of a deficiency. It prohibits supplemental assessments of a deficiency without notice of a deficiency.... In this regard, the majority misreads section 6213(a) to apply to all assessments. That section, however, reads only to require a notice of deficiency when there is a deficiency at stake. When no deficiency is involved, as is thé case before us, [because the IRS’s refund is a nonrebate refund] then the notice of deficiency is not required.”
1 later decision quote this exact passage · from the dissent“[Sjections 6204(b) [covering supplemental assessments] and 6213(a) prohibit the IRS from issuing a supplemental assessment without first issuing a notice of deficiency and giving the taxpayer an opportunity to contest the assessment in Tax Court. The Court finds no applicable exception to these procedural requirements. Section 6213(a) applies to all assessments; it does not distinguish between assessments intended to reclaim rebate refunds versus those intended to reclaim non-rebate refunds.”
1 later decision quote this exact passage · from the majority“The running of the period of limitations provided in section 6501 ... on the making of assessments_shall (after the mailing of a notice under section 6212(a)) be suspended for the period during which the Secretary is prohibited from making the assessment ... (and in any event, if a proceeding in respect of the deficiency is placed on the docket of the Tax Court, until the decision of the Tax court becomes final), and for 60 days thereafter.”
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.