Harper v. Rettig’s Empirical Analysis
2022
Citation profile
1 district ·
Relationships
Applies 26 U.S.C. § 7421 · 26 U.S.C. § 7602 · 26 U.S.C. § 7609 · 28 U.S.C. § 2201 · 28 U.S.C. § 2283 · 5 U.S.C. § 702
Relies on Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics · United States v. Testan · Larson v. Domestic & Foreign Commerce Corp. · United States v. King · Dugan v. Rank
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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“ascertain[] the correctness of any return, 5 The court allowed a John Doe to intervene in the proceedings, and it also permitted three amici to file briefs opposing the summons. See Coinbase, 2017 WL 5890052 , at , . Harper participated in the filing of one of these briefs, though he did so in a professional capacity and not, so far as the record reveals, based on a belief that his account information was implicated by the summons. - 7 - mak[e] a return where none has been made, determin[e] the liability of any person for any internal revenue tax or ... collect[] any such liability,”
1 later decision quote this exact passage · from the majoritye.g. Harper v. Werfel“limited to name, address, tax identification number, date of birth, account opening records, copies of passport or driver's license, all wallet addresses, and all public keys for all accounts/wallets/vaults”
1 later decision quote this exact passage · from the majoritye.g. Harper v. Werfel“ha[s] information that you have or had one or more accounts containing virtual currency but may not have properly reported your transactions involving virtual currency.”
1 later decision quote this exact passage · from the majoritye.g. Harper v. Werfel
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.