Thompson v. United States’s Empirical Analysis
308 F.2d 628 · 1962
Citation profile
20 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 25 later decisions — most recently November 1999 · most notably Henry S. Bloomgarden v. Charles B. Coyer (1973), Brown v. United States Department of Interior (1982)
20 federal appellate · 1 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 16 U.S.C. § 471 · 16 U.S.C. § 480 · 16 U.S.C. § 520 · 16 U.S.C. § 555 · 16 U.S.C. § 564 · 16 U.S.C. § 569 · 26 U.S.C. § 6213 · 26 U.S.C. § 7422
Relies on United States v. Felt & Tarrant Manufacturing Co. · Laskey Bros. of West Virginia, Inc. v. Warner Bros. Pictures, Inc. · State of Oklahoma v. State of Texas · Sutton v. United States · United States v. Wyoming
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Internal Revenue Act provides for complete and exclusive relief to taxpayers who feel aggrieved by the rulings of the Commissioner. Thus, it is clear that Congress has provided two, and only two, basic procedures by which a taxpayer may challenge the legality of a tax or an assessment: (1) he may decline to pay and, provided the proper steps are taken, he may have a determination of his problem before collection and payment of the tax. 26 U.S.C. § 6213 . This is commonly known as the Tax Court route, the decision in which may be reviewed on the record before the Court of Appeals; or (2) the taxpayer may pay the disputed tax and after exhausting the procedures on his claim for refund, he may sue in the United States District Court to recover the taxes paid. 26 U.S.C. § 7422 [Citations omitted and emphasis supplied.]”
1 later decision quote this exact passage · from the majority“[tjhis section is not as comprehensive as its words, separately considered, suggest. * * * [I]t is apparent that, while embracing only lands owned by the United States, it does not embrace all that are so owned. * * * Only where the United States has indicated that the lands are held for disposal under the land laws does the section apply; and it never applies where the United States directs that the disposal be only under other laws.”
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.