McGarry Inc. v. Frank E. Rose, Special Agent, Internal Revenue Service’s Empirical Analysis
344 F.2d 416 · 1965
Citation profile
27 federal appellate · 3 district ·
How this case has been cited
Cited by 40 later decisions (1 by the Supreme Court) — most recently February 2005 · most notably Donaldson v. United States (1971), United States v. Silvestri (1986)
27 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 Wong Sun v. United States · Silverthorne Lumber Co. v. United States · Nardone v. United States · United States v. Powell · Walder 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The record in the instant case shows that appellants were served with orders to show cause and petitions to enforce summonses, each of which fully apprized them of the nature of the relief sought by appellee. In the two-month interval between the issuing of the show cause order and the actual hearing thereon, appellants and their counsel had ample time to evaluate and study the petitions and show cause orders, and to file both short and lengthy motions to dismiss, as well'as an answer, all of which put in issue before the district court the contrary positions of the parties on this matter. A reading of the opinion in United States v. Powell, supra, leaves no doubt that the thrust thereof is to insure that a taxpayer obtain an adversary-type hearing in the district court prior to his being forced to comply with an administrative summons which he challenges in good faith. That the procedure followed in the instant case fully complies with the essential requirements of the Powell decision appears so clearly from the record herein as to preclude any need for further discussion of appellants’ contentions with reference thereto.””
3 later decisions 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.