Sappington v. United States’s Empirical Analysis
408 F.2d 817 · 1969
Citation profile
5 federal appellate · 2 state decisions
How this case has been cited
Cited by 13 later decisions — most recently August 2002
5 federal appellate · 2 state decisions
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
Applies 26 U.S.C. § 2033 · 26 U.S.C. § 2035 · 26 U.S.C. § 6532
Relies on Scripps-Howard Radio, Inc. v. Federal Communications Commission · United States v. Garbutt Oil Co. · United States v. Andrews · Nemours Corp. v. United States · United States v. Hancock Bank, Trustee of the Estate of Anna F. C. Martin, Hancock Bank, Trustee of the Estate of Anna F. C. Martin 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A claim seeking refund upon one asserted fact situation may not be amended out of time so as to require an investigation of matters not germane to the original claim . . . While an amendment which only makes more definite matters already within the Commissioner's knowledge is permissible, the fact of specification of the original claim tends to confine the administrative investigation to that issue.”
1 later decision quote this exact passage · from the majority“[a] claim seeking refund upon one asserted fact situation may not be amended out of time so as to require an investigation of matters not germane to the original claim.”
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.