Brown v. United States’s Empirical Analysis
391 F.2d 653 · 1968
Citation profile
9
cited by 9 later decisions
December 1976
most recently cited
3 federal appellate ·
Relationships
Applies 26 U.S.C. § 6212 · 26 U.S.C. § 7503
Relies on Helvering v. City Bank Farmers Trust Co. · Helvering v. City Bank Farmers Trust Co.
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We do not agree with the plaintiffs’ position that the legal effect of section 7503 * * * is to treat their return as if it was filed on Sunday so that the limitation period on assessment of a deficiency begins to run from Sunday, April 15. Section 7503 merely considers the performance of such act on the next succeeding business day as being timely and does not operate to negate the effect of the actual date of performance for other purposes, i.e., the actual date of filing for commencing the limitation period on assessments. By its terms, section 7503 does not purport to diminish the statute of limitations for making assessments.”
1 later decision quote this exact passage“When the last day prescribed under authority of the internal revenue laws for performing any act falls on Saturday, Sunday, or a legal holiday, the performance of such act shall be considered timely if it is performed on the next succeeding day which is not a Saturday, Sunday, or a legal holiday.”
1 later decision quote this exact passage
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.