Laing v. United States’s Empirical Analysis

Citation profile

274 federal appellate · 32 district · 13 state decisions

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

1. “Where there has been no tax return filed, the deficiency is the amount of tax due.”

   6 later decisions quote this exact passage · from the majority
   e.g. Robert J. McGlone v. Commissioner of Internal Revenue · Matthews v. Commissioner

2. “The 'assessment,' essentially a bookkeeping notation, is made when the Secretary or his delegate establishes an account against the taxpayer on the tax rolls.”

   5 later decisions quote this exact passage · from the dissent
   e.g. Hibbs Director Arizona Department of Revenue v. Winn et al. · Keado v. United States

3. “Notwithstanding the provisions of section 7421(a), the making of such assessment or the beginning of such proceeding or levy during the time such prohibition is in force may be enjoined by a proceeding in the proper court.”

   3 later decisions quote this exact passage · from the dissent
   e.g. 629 F. Supp. 333 - Rodriguez v. United States · Cool Fuel, Inc. v. Connett