United States v. Heffner’s Empirical Analysis
420 F.2d 809 · 1969
Citation profile
132 federal appellate · 36 district · 26 state decisions
How this case has been cited
Cited by 267 later decisions (1 by the Supreme Court) — most recently August 2020 · most notably United States v. Caceres (1979), Doe v. Hampton (1977)
132 federal appellate · 36 district · 26 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. § 7205
Relies on Miranda v. State of Arizona Vignera · United States Accardi v. Shaughnessy · Service v. Dulles · Vitarelli v. Seaton · Yellin 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 267 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An agency of the government must scrupulously observe rules, regulations, or procedures which it has established. When it fails to do so, its action cannot stand and courts will strike it down.”
20 later decisions quote this exact passage · from the majority“As a special agent, I have the function of investigating the possibility of criminal tax fraud.”
4 later decisions quote this exact passage · from the majority“It is of no significance that the procedures or instructions which the IRS has established are more generous than the Constitution requires.”
3 later decisions 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.