United States v. Havner’s Empirical Analysis
1937
Citation profile
5 federal appellate · 2 district ·
How this case has been cited
Cited by 8 later decisions — most recently March 1965
5 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. § 276
Relies on Bowers v. New York & Albany Lighterage Co. · Davis v. Elmira Savings Bank · United States v. Updike · Cook Co Nat Bank v. United States · Davis v. Elmira Sav Bank
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * the taxpayer hereby expressly waives— ****** “2. The benefit of any statute of limitations affecting the collection of the liability sought to be compromised, and in the event of the rejection of the offer, expressly consents to the extension of any statute of limitations affecting the collection or the liability sought to be compromised by the period of time (not to exceed two years) 'elapsed between the date of the filing of this offer and the date on which final action thereon is taken.””
1 later decision quote this exact passage · from the majority““ * * * the proponent hereby expressly waives: ****** “2. The benefit of any statute of limitations applicable to the assessment and/or collection of the liability sought to be compromised, and agrees to the suspension of the running of the statutory period of limitations on assessment and/or collection for the period during which this offer is pending and for one year thereafter.””
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.