Conner v. United States’s Empirical Analysis
434 F.3d 676 · 2006
Citation profile
1 federal appellate · 1 district ·
Relationships
Applies 26 U.S.C. § 7609
Relies on United States v. Powell · Church of Scientology of California v. United States · United States v. Stuart · Hillman v. Internal Revenue Service · Groder 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“When an interested party challenges enforcement of an IRS summons, under United States v. Powell, 379 U.S. 48 , 85 S.Ct. 248 , 13 L.Ed.2d 112 (1964), the initial burden rests with the government to establish a prima facie showing of good faith in issuing the summons, requiring proof that the IRS has satisfied the following four elements: (1) the investigation is being conducted for a legitimate purpose; (2) the inquiry is relevant to that purpose; (3) the information sought is not already in the possession of the IRS; and (4) the administrative steps required by the Internal Revenue Code have been followed.”
2 later decisions 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.