Robert v. United States’s Empirical Analysis

Citation profile

6 federal appellate · 1 district ·

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.

1. “Discovery is not necessary in every summons action, and, in fact, the sum mary nature of proceedings on an IRS summons militate against expansive discovery. However, in many cases, some discovery is- appropriate and should be allowed. To strike a balance between the summary nature of summons proceedings and the relative disadvantage taxpayers face regarding access to information, we have held that discovery in a summary summons proceeding is appropriate where a taxpayer makes a substantial preliminary showing that enforcement of a summons would result in an abuse of the court’s process.”

   2 later decisions quote this exact passage · from the majority
   e.g. United States v. Norwood · United States v. Norwood

2. “The Supreme Court has stated that courts should be slow to erect barriers to enforcement of [respondent's] summonses where the summonses are being used to further [respondent's] mission of effectively investigating taxpayer liabilities”

   1 later decision quote this exact passage · from the majority
   e.g. Moore v. Comm'r

3. “if the summons had been issued for an improper purpose, such as to harass the taxpayer or to put pressure on him to settle a collateral dispute, or for any other purpose reflecting on the good faith of the particular investigation.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Norwood