Luhring v. Glotzbach’s Empirical Analysis
304 F.2d 556 · 1962
Citation profile
32 federal appellate · 3 district ·
How this case has been cited
Cited by 77 later decisions — most recently May 1992 · most notably Frieling v. Commissioner (1983), Alta Sierra Vista, Inc. v. Commissioner (1974)
32 federal appellate · 3 district ·
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
Relies on Welch v. Schweitzer · Gregory v. United States · Pfeffer v. Commissioner · Clark's Estate v. Commissioner of Internal Revenue
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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) . . . [N]o assessment of a deficiency in respect of any tax imposed by subtitle A or B . . . and no levy or proceeding in court for its collection shall be made, begun, or prosecuted until such notice [as provided in section 6212] has been mailed to the taxpayer Notwithstanding the provisions of section 7421(a), the making of such assessment or the beginning of such proceeding or levy during the time such prohibition is in force may be enjoined by a proceeding in the proper court.””
1 later decision quote this exact passage · from the majority“The statute, however, does not require service of actual notice upon the taxpayer but merely the mailing of the notice to him by certified or registered mail at his last known address. * * * No one questions the power of Congress to make this provision in consideration of the administrative difficulties involved in the discharge of the Commissioner's duties * * *.”
1 later decision quote this exact passage · from the majoritye.g. Brown v. Lethert“(a) In general. — If the Secretary or his delegate determines that there is a deficiency in respect of any tax imposed [on income] * * *, he is authorized to send notice of such deficiency to the taxpayer by certified mail or registered mail. 5”
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.