Mitchell v. Riddell’s Empirical Analysis
402 F.2d 842 · 1968
Citation profile
12 federal appellate · 5 district ·
How this case has been cited
Cited by 34 later decisions (2 by the Supreme Court) — most recently April 1995 · most notably Bob Jones University v. Simon (1974), Alexander v. "Americans United" Inc. (1974)
12 federal appellate · 5 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 United States v. Sherwood · United States v. Lee · United States v. Shaw · Keifer v. Reconstruction Finance Corp. · Minnesota 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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In a case of actual controversy within its jurisdiction, except with respect to Federal taxes, any court of the United States, upon the filing of an appropriate pleading, may declare the rights and other legal relations of any interested party seeking such declaration, whether or not further relief is or could be sought. Any such declaration shall have the force and effect of a final judgment or decree and shall be reviewable as such.”
2 later decisions quote this exact passage · from the majority“actual controversy” and the express exception of the Declaratory Judgment Act removing from the courts the power to declare rights “with respect to federal taxes” the court cannot presume to speak for the commissioner or take over his duty to pass upon the tax status of organizations____ 402 F.2d at 846 , quoting from Jolles Foundation, Inc. v. Moysey, 250 F.2d 166 (2d Cir.1957). One court has noted that”
2 later decisions quote this exact passage · from the majority““Appellants are not without a remedy. The Congress has provided ample machinery for the settlement of income tax controversies. In the event a tax is assessed against the Foundation, judicial review of such assessment may be sought under the provisions of 26 U.S.C. § 7422 by paying the tax and seeking a refund in the district court, or by petitioning the Tax Court of the United States, prior to paying the tax, and in the event of an adverse decision by the Tax Court by petitioning this Court to review the decision of the Tax Court.” 402 F.2d at 847 .”
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.