Wozniak’s Empirical Analysis
1979
Citation profile
How this case has been cited
Cited by 9 later decisions — most recently August 2014
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. § 6532 · 26 U.S.C. § 7422
Relies on Jarvis
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.
“To invoke this court’s jurisdiction in a tax case, the deficiency must be fully paid and a timely claim for refund filed with the Internal Revenue Service, 26 U.S.C. § 7422 (a).... A petitioner must further demonstrate the claim for refund has been either disallowed or ignored by the Internal Revenue Service, 26 United States Code § 6532 (a)(1)....”
1 later decision quote this exact passage
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.