Gunn v. Mathis’s Empirical Analysis
1958
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 9 later decisions — most recently May 1983
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. § 6213 · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6325 · 26 U.S.C. § 7481 · 26 U.S.C. § 7485 · 28 U.S.C. § 1391 · 28 U.S.C. § 1392 · 28 U.S.C. § 1406
Relies on Williams v. Fanning · Stewart v. Baltimore & Ohio Railroad · Leon F. Urbain and Loxit Systems, Inc. v. Knapp Brothers Manufacturing Company, Al Levinson, Charles Levinson, and Robert Levinson · United States v. Onan · Ventura Consolidated Oil Fields v. Rogan
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The only thing settled by the opinion of the Court of Appeals in the instant case is the tax liability for the years 1945 and 1946. The case was remanded to the Tax Court as to the years 1942, 1943 and 1944 and, as above pointed out, the Tax Court is free to determine the amount of the deficiency, if any, chargeable to the taxpayer. It is true that the Court of Appeals stated that it would have permitted the Tax Court decision to stand if it had not been for the unrealistic finding with regard to the opening net worth. Nevertheless, in view of the unrealistic finding the court reversed the Tax Court decision and remanded the case to the Tax Court with the privilege given to the parties to introduce any additional evidence relating to the amounts of the deficiencies, if any, for the years 1942, 1943 and 1944.” 5”
2 later decisions quote this exact passage · from the majority“Notwithstanding the provisions of section 7421(a), the making of such assessment or the beginning of such proceeding or levy during the time such prohibition is in force may be enjoined by a proceeding in the proper court.”
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.