United States v. Kulukundis’s Empirical Analysis
329 F.2d 197 · 1964
Citation profile
17 federal appellate · 2 district ·
How this case has been cited
Cited by 21 later decisions — most recently June 2005
17 federal appellate · 2 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 Phillips v. Commissioner · Reisman v. Caplin · Phillips v. Commissioner · Cannon v. Ellis · In re Albert Lindley Lee Memorial Hospital
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(I)t would be a quite different matter for the courts to construct a condition whereby the Government's bringing a civil suit rather than relying solely on summary methods of tax collection would deprive it of a remedy which the letter of the Code assuredly gives particularly when Congress, in § 7605(b), prescribed such provisions for the protection of taxpayers as it wished to make.”
2 later decisions quote this exact passage · from the majority“seems to destroy the basis underlying decisions of this court which authorized applications to vacate [an IRS] summons (and appeals from their denial) in advance of any judicial proceeding by the Government for their enforcement.”
1 later decision quote this exact passage · from the majority“we would not wish to be committed to the district judge's view that the summonses were unauthorized insofar as they sought to inquire into the existence of tax liability.”
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.