Smith v. United States’s Empirical Analysis
328 F.3d 760 · 2003
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 19 later decisions — most recently September 2024
7 federal appellate · 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
Applies 26 U.S.C. § 6212 · 26 U.S.C. § 6213 · 26 U.S.C. § 6230 · 26 U.S.C. § 6320 · 26 U.S.C. § 6601 · 26 U.S.C. § 6621 · 26 U.S.C. § 6659 · 26 U.S.C. § 7121
Relies on Botany Worsted Mills v. United States · National Union Fire Insurance Co. of Pittsburgh v. Textron Financial Corp. · Maxwell v. Commissioner · Daniels v. City of Arlington · Fehlhaber v. Fehlhaber
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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If you later file a claim and the Service disallows it, you may file suit for refund in a district court or in the United States Claims Court, but you may not file a petition with the United States Tax Court.”
1 later decision quote this exact passage · from the majoritye.g. Nichols v. Comm'r“I understand that by signing this waiver, I will not be able to contest these years in the United States Tax Court, unless additional deficiencies are determined for these years.”
1 later decision quote this exact passage · from the majoritye.g. Nichols v. Comm'r“[Your consent] will not prevent us from later determining, if necessary, that you owe additional tax * * *.”
1 later decision quote this exact passage · from the majoritye.g. Nichols v. Comm'r
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.