United States v. McCarthy’s Empirical Analysis
514 F.2d 368 · 1975
Citation profile
76 federal appellate · 8 district · 2 state decisions
How this case has been cited
Cited by 121 later decisions (1 by the Supreme Court) — most recently January 1998 · most notably United States v. National Bank (1978), United States v. Davis (1981)
76 federal appellate · 8 district · 2 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. § 6501 · 26 U.S.C. § 6651 · 26 U.S.C. § 7602 · 26 U.S.C. § 7604 · 26 U.S.C. § 7605
Relies on United States v. Powell · Donaldson v. United States · Couch v. United States · Reisman v. Caplin
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 121 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“‘Although our proposed procedure for summons enforcement contemplates that provision for an evidentiary hearing be an integral part of the proceedings, implicit in our design is the realization that not every summons enforcement proceeding will require an evidentiary hearing. Thus, if the person summoned neither puts in issue allegations of the complaint nor raises proper affirmative defenses, no evidentiary hearing will be required; the matter can be decided on the pleadings.’ 514 F.2d at 373 .”
3 later decisions quote this exact passage · from the majority““must show that the investigation will be conducted pursuant to a legitimate purpose, that the inquiry may be relevant to the purpose, that the information sought is not already within the Commissioner’s possession, and that the administrative steps required by the Code have been followed . . . ””
3 later decisions quote this exact passage · from the majority““1. The Secretary or his delegate would file a complaint accompanied by an affidavit of the agent who issued the summons, seeking enforcement- The complaint should separately allege compliance with each of the requirements of the Powell test of. enforceability. The affidavit should support these allegations.””
2 later decisions 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.