Taylor v. Allan’s Empirical Analysis
204 F.2d 485 · 1953
Citation profile
8 federal appellate · 2 district ·
How this case has been cited
Cited by 15 later decisions — most recently May 2007
8 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. § 275 · 26 U.S.C. § 276 · 28 U.S.C. § 2201
Relies on Ritter v. United States · Graham v. du Pont · Sumi v. Young · Tomlinson v. Smith · Calhoun 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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is manifest that the very purpose of the action, is to obtain a decree declaring certain assessments of federal income taxes, penalties and interest to be null and void upon the ground that they are barred by the statute of limitations. • The limitation is not applicable in case of false or fraudulent returns with intent to evade taxes or of failure to file a return. 26 U.S.C.A. § 276 (a). Any controversy growing out of the allegations of the complaint could relate only to federal taxes and the. liability therefor. It is not sufficient to say that the controversy relates only to procedure in the method of collection when the decree prayed for would not only affect, but would prevent, the collection of federal taxes which the collector claims are due and owing. The action is, therefore, one ‘with respect to Federal taxes’ as contemplated by the Declaratory Judgments Statute.” (Emphasis supplied.)”
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.