In Re: Stuart Becker’s Empirical Analysis
2005
Citation profile
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.
“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.