430 F. Supp. 2d 1254 - Brewer v. Commissioner’s Empirical Analysis
2006
Citation profile
1 district ·
Relationships
Applies 26 U.S.C. § 6213 · 26 U.S.C. § 7421 · 26 U.S.C. § 7433 · 28 U.S.C. § 1331 · 28 U.S.C. § 2410 · 28 U.S.C. § 2674 · 28 U.S.C. § 2680
Relies on Conley v. Gibson · United States v. Sherwood · Federal Deposit Insurance v. Meyer · United States v. Nordic Village, Inc. · Soriano 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Government first argues that the making of an assessment is not a collection activity, asserting that an assessment is a mere determination of tax liability which must precede any collection action by the IRS. The Government is correct that a mere assessment is not a collection action. However, as the Government acknowledges, a notice and demand for payment constitute a collection action, as does the filing of a notice of tax lien.”
1 later decision quote this exact passage
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.