Rich v. Commissioner’s Empirical Analysis
1957
Citation profile
28 federal appellate · 1 state decisions
How this case has been cited
Cited by 55 later decisions — most recently August 2020 · most notably Charlson Realty Co. v. United States (1967), Moffat v. Commissioner (1966)
28 federal appellate · 1 state decisions
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. § 7502
Relies on Caminetti v. United States · United States v. American Trucking Associations · Sorrells v. United States · Price v. Johnston · Brotherhood of Railroad Trainmen v. Baltimore & Ohio Railroad
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]his is a hard case presenting a grossly inequitable situation, but neither the Tax Court nor this Court has any authority to relieve the taxpayer from the clear jurisdictional requirements of the law.”
4 later decisions quote this exact passage · from the concurrence“(w)ithin 90 days . . . after the notice of deficiency . . . is mailed . . ., the taxpayer may file a petition with the Tax Court for a redetermination of the deficiency.”
3 later decisions quote this exact passage · from the concurrence“The petitioner here has done everything in its power that could reasonably be done and is entirely without fault. The fault and negligence was manifestly that of government employees — whether employees in the mail service or employees in the Internal Revenue Department would seem to be immaterial. They were government employees and we think the government should not be permitted to take advantage of the negligence or fault of its own employees to defeat this taxpayer in its efforts to have its day in court. 198 F.2d at 192 .”
2 later decisions 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.