Feldman v. Commissioner’s Empirical Analysis
1994
Citation profile
19 federal appellate ·
How this case has been cited
Cited by 58 later decisions — most recently June 2013 · most notably Tefel v. Reno (1999), Roberts v. Commissioner (2003)
19 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. § 6013 · 26 U.S.C. § 6501 · 26 U.S.C. § 6621
Relies on Welch v. Helvering · Heckler v. Community Health Services of Crawford County, Inc. · Office of Personnel Management v. Richmond · Director, Office of Workers' Compensation Programs v. Broyles · Stange 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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“before the expiration of the time prescribed in this section for the assessment of any tax imposed by this title....”
3 later decisions quote this exact passage · from the majority“'(1) words, acts, conduct or acquiescence causing another to believe in the existence of a certain state of things; (2) wilfulness or negligence with regard to the acts, conduct or acquiescence; and (3) detrimental reliance by the other party upon the state of things so indicated.'”
1 later decision quote this exact passage · from the majority“equitable estoppel will lie against the government only in the most extreme circumstances”
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.