Frazier v. Phinney’s Empirical Analysis
1959
Citation profile
1 federal appellate ·
Relationships
Applies 18 U.S.C. § 1905 · 26 U.S.C. § 55 · 26 U.S.C. § 7213 · 28 U.S.C. § 1340
Relies on Hickman v. Taylor · United States Touhy v. Ragen · Boske v. Comingore · Blair v. Oesterlein Machine Co. · Crawford v. Hubbell
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Plaintiffs contend that defendant has given no explanation whatsoever for these alleged deficiencies and penalties, stating only that ‘this determination of your income tax liability has been made on the basis of information on file in this office.’ They allege that they made many requests for an explanation and for a statement of facts upon which the alleged deficiencies were based and that all such requests were summarily refused by defendant.” (p. 408)”
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.