In Re: Roger Pransky’s Empirical Analysis
Citation profile
1 district ·
How this case has been cited
Cited by 23 later decisions — most recently February 2020
1 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 United States v. Dalm · Rothensies v. Electric Storage Battery Co. · Rosenman v. United States · F/s Airlease II Inc v. Simon S-J Swig Investment Company Aircraft Trust No F/s Airlease II Inc Simon S-J F/s Airlease II Inc · Charlson Realty Co. v. United States
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The second but explained the factual and legal bases for the refunds he claimed in both requests. They added detail to the first requests, but the facts and legal theories on which Pransky sought relief had not changed. Thus, although the requests Pransky submitted did not look identical, the second requests are best characterized as motions for reconsideration of the first requests, or as reiterations of the same claims.... And, importantly, the IRS denied the first requests on the same ground&emdash;the § 6511 reasoning&emdash;that Pransky explicitly argued in his second requests.”
1 later decision quote this exact passage · from the majority“The District Court also affirmed the Bankruptcy Court’s holding that [26 U.S.C.] § 6511 did not preclude Pransky from obtaining refunds from the payments he made toward his 1986 and 1987 taxes because he had paid those taxes within three years preceding his requests for refunds. As the IRS points out, however, there was no reason for the District Court to reach this issue because, without the 1984 and 1985 credits, there were no overpayments from 1986 or 1987 to refund.”
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.