O'Connor v. O'Connell’s Empirical Analysis
253 F.2d 365 · 1958
Citation profile
41 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 58 later decisions (2 by the Supreme Court) — most recently November 1991 · most notably United States v. Powell (1964), Reisman v. Caplin (1964)
41 federal appellate · 3 district · 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. § 276 · 26 U.S.C. § 7602
Relies on Cobbledick v. United States · Alexander v. United States · Interstate Commerce Commission v. Baird · Ellis v. Interstate Commerce Commission · Adams v. Maryland
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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“there remains nothing for (the district court) to do.”
5 later decisions quote this exact passage · from the majority“that before the tax authorities are entitled to a district court order enforcing a summons directing a taxpayer to testify as to a closed year they must establish to the district court's satisfaction that a reasonable basis exists for a suspicion of fraud, or put another way, that there is probable cause to believe that the taxpayer was guilty of fraud in a statute barred year.”
1 later decision quote this exact passage · from the majoritye.g. Lash v. Nighosian“the Secretary or his delegate, when a court order is needed to enforce compliance with a summons to testify as to a `closed' year, should be required to establish to the court's satisfaction that there is probable cause for an investigation into such a year.”
1 later decision quote this exact passage · from the majoritye.g. Lash v. Nighosian
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.