McDonnell v. United States’s Empirical Analysis
180 F.3d 721 · 1999
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 28 later decisions — most recently November 2011 · most notably Blakely v. United States (2002), Kikalos v. Commissioner (1999)
12 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. § 163 · 26 U.S.C. § 7422
Relies on Boyd v. United States · Redlark v. Commissioner · Miller v. United States · Charter Company v. United States · Salyersville National Bank 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The regulations promulgated pursuant to § 7422(a) state that “[t]he claim must set forth in detail each ground upon which a credit or refund is claimed and facts sufficient to apprise the Commissioner of the exact basis thereof.” Treas. Reg. § 301.6402-2 (b)(l). When a party fails to state with specificity the grounds for the refund, the court is without jurisdiction to entertain the action. See Salyersville Nat'l Bank v. United States, 613 F.2d 650, 651 (6th Cir.1980). “Federal courts have no jurisdiction to entertain taxpayer allegations that impermissibly vary or augment the grounds originally specified by the taxpayer in the administrative refund claim.” Charter Co. v. United States, 971 F.2d 1576, 1579 (11th Cir.1992).”
2 later decisions quote this exact passage · from the majority“to a trade or business. 26 At the outset the Government argues that the Regulation (quoted here with emphasis added) is not only valid but is dispositive of this case 9 27 [P]ersonal interest includes interest-- 28 (A) Paid on underpayments of individual Federal, State or local income taxes and on indebtedness used to pay such taxes (within the meaning of S1.168-8T), regardless of the source of the income generating the tax liability. 29 While the Government says that deferred DISC-related tax liability is an”
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.