Perkal v. Rayunec’s Empirical Analysis
1964
Citation profile
2 federal appellate · 1 district · 1 state decisions
Relationships
Relies on Reisman v. Caplin · Foster v. United States · McMann v. Securities & Exchange Commission · De Masters v. Arend · In re Albert Lindley Lee Memorial Hospital
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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It would therefore appear that the case law clearly states that a taxpayer is without standing to defeat compliance with a Section 7602(2) summons directed to a third party asking for production of that party’s own records. Reisman v. Caplin, 375 U.S. 440 , 84 S.Ct. 508 , 11 L.Ed.2d 459 (1964) on which the taxpayer relies, does not support his position. Although the Court stated there by way of dicta that parties affected by a disclosure may appear and assert their claims, there is no reference made to the situation at bar in which the taxpayer seeks to quash a summons directed to an independent bank for production of its own records, (emphasis in origihal).”
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.