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← 407 F.3d 89 - In Re: Stuart Becker

In Re: Stuart Becker’s Empirical Analysis

2005

Citation profile

10
cited by 10 later decisions
February 2014
most recently cited

Relationships

Applies 26 U.S.C. § 3402 · 26 U.S.C. § 6404 · 26 U.S.C. § 6501 · 26 U.S.C. § 6672

Relies on Heckler v. Community Health Services of Crawford County, Inc. · Baldwin County Welcome Center v. Brown · Order of Railroad Telegraphers v. Railway Express Agency, Inc. · United States v. Dalm · Chase Securities Corp. v. Donaldson

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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Estoppel is an equitable doctrine invoked to avoid injustice in particular cases.... [T]he party claiming the es-toppel must have relied on its adversary’s conduct in such a manner as to change his position for the worse, and that reliance must have been reasonable in that the party claiming the estoppel did not know nor should it have known that its adversary’s conduct was misleading. ... Further, the truth concerning these material facts must be .unknown to the other party claiming the benefit of the estoppel, not only at the time of the conduct which amounts to a representation or concealment, but also at the time when that conduct is acted upon by him. If, at the time when he acted, such party had knowledge of the truth, or had the means by which with reasonable diligence he could acquire the knowledge so that it would be negligence on his part to remain ignorant by not using those means, he cannot claim to have been misled by relying upon the representation or concealment....”
    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.