Magnus’s Empirical Analysis

Citation profile

1 federal appellate · 2 district ·

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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““(b) Restriction on Examination of Taxpayer — No taxpayer shall be subjected to unnecessary examination or investigations, and only one inspection of a taxpayer’s books of account shall be made for each taxable year unless the taxpayer requests otherwise; or unless the Secretary or his delegate notifies the taxpayer in writing that an additional inspection is necessary.””

   3 later decisions quote this exact passage · from the majority
   e.g. United States v. Powell · United States v. Giordano

2. ““The examination which IRS seeks is of third parties and not a further examination of the taxpayer. The inspection desired is of corporate books and accounting firm papers and not of the taxpayer’s books. Under these circumstances, the taxpayers have no standing to quash the summonses which call neither for their further appearance or examination nor for further production of their books.””

   1 later decision quote this exact passage · from the majority
   e.g. Bouschor v. United States

3. ““Ours courts should not permit interventions which delay government action at the investigation stage unless the interest asserted is direct and immediate.””

   1 later decision quote this exact passage · from the majority
   e.g. In re the Commissioner of Internal Revenue