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← 44 TC 673 - Williams v. Commissioner

Williams v. Commissioner’s Empirical Analysis

1965

Citation profile

3
cited by 3 later decisions
November 1987
most recently cited

How this case has been cited

Cited by 3 later decisions — most recently November 1987

10196519701980decided

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. § 6871

Relies on Green v. Vanston Bondholders Protective Committee · BancoKentucky Co.'s Receiver v. National Bank of Kentucky's Receiver · Comas, Inc. v. Commissioner · French & Co. v. Commissioner · Psaty & Fuhrman, Inc. v. Stimson

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.

  1. “(a) Immediate Assessment. — Upon the adjudication of bankruptcy of any taxpayer In any liquidating proceeding, the filing or (where approval is required by the Bankruptcy Act) the approval of a petition of, or the approval of a petition against, any taxpayer in any other bankruptcy proceeding, or the appointment of a receiver for any taxpayer in any receivership proceeding before any court of the United States or of any State or Territory or of the District of Columbia, any deficiency (together with all interest, additional amounts, or additions to the tax provided by law) determined by the Secretary or his delegate in respect of a tax imposed by subtitle A or B upon such taxpayer shall, despite the restrictions imposed by section 6213(a) upon assessments, be immediately assessed if such deficiency has not theretofore been assessed in accordance with law. [Emphasis added.]”
    1 later decision quote this exact passage
  2. “but no petition for any such redetermination shall be filed with the Tax Court after * * * the appointment of the receiver.”
    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.