Smith v. United States’s Empirical Analysis
2012
Citation profile
2 federal appellate ·
Relationships
Applies 26 U.S.C. § 6015 · 26 U.S.C. § 6213 · 26 U.S.C. § 6512 · 26 U.S.C. § 6513 · 26 U.S.C. § 7422 · 28 U.S.C. § 1295 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 1491
Relies on Liljeberg v. Health Services Acquisition Corp. · Flora v. United States · Henke v. United States · Horne v. Flores · Rick's Mushroom Service, Inc. 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) The district courts shall have original jurisdiction, concurrent with the United States Court of Federal Claims, of: (1) Any civil action against the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, or any penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected under the internal-revenue laws_”
2 later decisions quote this exact passage · from the majority“The Unite[d] States Court of Federal Claims ... shall have jurisdiction to render judgment on an action by an interested party objecting to a solicitation for bids or proposals for a proposed contract or to a proposed award or the award of a contract or any alleged violation of statute or regulation in connection with a procurement or a proposed procurement.”
1 later decision quote this exact passage · from the majority
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.