United States v. Forma’s Empirical Analysis
42 F.3d 759 · 1994
Citation profile
18 federal appellate · 6 district · 2 state decisions
How this case has been cited
Cited by 64 later decisions — most recently November 2020 · most notably Central Vermont Public Service Corp. v. Herbert (2003), Presidential Gardens Associates 1984-2 v. United States Secretary of Housing and Urban Development (1999)
18 federal appellate · 6 district · 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. § 6502 · 26 U.S.C. § 6511 · 26 U.S.C. § 7422 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on United States v. Testan · United States v. Sherwood · Federal Deposit Insurance v. Meyer · American Manufacturers Mutual Insurance v. United States · Bull 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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a claim for refund or credit has been duly filed with the Secretary, according to the provisions of law in that regard, and the regulations of the Secretary established in pursuance thereof.”
2 later decisions quote this exact passage · from the majority“Claim for credit or refund of an overpayment of any tax imposed by this title in respect of which tax the taxpayer is required to file a return shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.”
1 later decision quote this exact passage · from the majority“a party sued by the United States may recoup damages * * * so as to reduce or defeat the government's claim * * * though no affirmative judgment * * * can be rendered against the United States.”
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.