447 F. Supp. 385 - Crouch v. Commissioner’s Empirical Analysis
1978
Citation profile
1 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 12 later decisions — most recently November 2011
1 federal appellate · 1 district · 1 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. § 6695 · 26 U.S.C. § 6696 · 26 U.S.C. § 7421 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Bob Jones University v. Simon · Shaw 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Penalty assessed as tax. — The penalties and liabilities provided by this sub-chapter [B] shall be paid upon notice and demand by the Secretary or his delegate, and shall be assessed and collected in the same manner as taxes. Except as otherwise provided, any reference in this title [26 U.S.C.] to ‘tax’ imposed by this title shall be deemed also to refer to the penalties and liabilities provided by this sub-chapter.”
2 later decisions quote this exact passage · from the majority“(N)o suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person.”
1 later decision quote this exact passage · from the majoritye.g. Farrell v. Rouan
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.