Scrimgeour v. Internal Revenue’s Empirical Analysis
149 F.3d 318 · 1998
Citation profile
13 federal appellate · 2 district ·
How this case has been cited
Cited by 36 later decisions (1 by the Supreme Court) — most recently August 2015 · most notably Doe v. Chao Secretary of Labor (2004), Nelson-Salabes Incorporated v. Morningside Development Llc (2002)
13 federal appellate · 2 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. § 138 · 26 U.S.C. § 25 · 26 U.S.C. § 6103 · 26 U.S.C. § 72 · 26 U.S.C. § 7430 · 26 U.S.C. § 7431 · 26 U.S.C. § 7432 · 26 U.S.C. § 7433
Relies on United States v. United States Gypsum Co. · Robinson v. Shell Oil Co. · Smith v. Wade · Ardestani v. Immigration & Naturalization Service · O'Sullivan v. Felix
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an act committed 'without grounds for believing it to be lawful, or by flagrantly disregarding others' rights under the Act.' ”
3 later decisions quote this exact passage · from the majority“[T]he $1,000.00 statutory damage award specified in I.R.C. § 7431(c)(1)(A) is included for the benefit of taxpayers. Actual damages for the invasion of privacy that occurs when tax returns are wrongfully disclosed can be hard to quantify. In order to encourage taxpayers to act as “private attorneys general” and pursue suits against the IRS for violations of I.R.C. § 6103, Congress enacted the statutory damages provision to ensure that in meritorious cases of wrongful release a taxpayer would not walk away from the courthouse empty handed for failure of proving actual damages.”
2 later decisions quote this exact passage · from the dissente.g. Doe v. Chao · Doe v. Chao“‘the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed.’”
2 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.