Rogan v. Ferry’s Empirical Analysis
154 F.2d 974 · 1946
Citation profile
10 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 22 later decisions — most recently May 1988
10 federal appellate · 1 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
Relies on Tucker v. Alexander · United States v. Kales · Lang v. Commissioner · United States v. Pierotti · Kales 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) * * * No suit or proceeding shall be maintained in any court for the recovery of any * * * tax alleged to have been erroneously * * * collected, * * * until a claim for refund or credit has been duly filed with the Secretary or his delegate * * * ””
3 later decisions quote this exact passage · from the majority“■ “It is of c.ourse the law that a suit for refund of taxes must be based on a claim previously filed with the Commissioner, and that the claim must set forth in detail each ground on which a refund is claimed and facts sufficient to. apprise, the Commissioner of the exact basis thereof.” (Emphasis supplied.) 3”
2 later decisions quote this exact passage · from the majority““In presenting a claim for refund to the Commissioner a taxpayer is required by section 3772 [predecessor to the present § 7422] to conform to the regulations established by the Secretary of the Treasury. * * * “[1] It is of course the law that a suit for refund of taxes must be based on a claim previously filed with the Commissioner, and that the claim must set forth in detail each ground on which a refund is claimed and facts sufficient to apprise the Commissioner of the exact basis thereof.””
1 later decision quote this exact passage · from the majoritye.g. Moser v. Wood
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.