Commissioner v. Lundy’s Empirical Analysis
1996
Citation profile
211 federal appellate · 59 district · 14 state decisions
How this case has been cited
Cited by 666 later decisions (10 by the Supreme Court) — most recently March 2025 · most notably Desert Palace, Inc. v. Costa (2003), City of Rockwall v. Hughes (2008)
211 federal appellate · 59 district · 14 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.
Appellate journey
reviewedLundy v. Internal Revenue Service (from Fourth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 6213 · 26 U.S.C. § 6501 · 26 U.S.C. § 6511 · 26 U.S.C. § 6512 · 26 U.S.C. § 6513 · 26 U.S.C. § 6651 · 26 U.S.C. § 6696 · 26 U.S.C. § 7422
Relies on United States v. Detroit Timber & Lumber Co. · Flora v. United States · Badaracco v. Commissioner · Sullivan v. Stroop · Sorenson v. Secretary of the Treasury
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 666 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The interrelationship and close proximity of these provisions of the statute presents a classic case for application of the normal rule of statutory construction that identical words used in different parts of the same act are intended to have the same meaning.”
19 later decisions quote this exact passage · from the majority“A taxpayer seeking a refund of overpaid taxes ordinarily must file a timely claim for a refund with the IRS under 26 U.S.C. § 6511 . That section contains two separate provisions for determining the timeliness of a refund claim. It first establishes a filing deadline: The taxpayer must file a claim for a refund “within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.” 26 U.S.C. § 6511 (b)(1) (incorporating by reference 26 U.S.C. § 6511 (a)). It also defines two “look-back” periods: If the claim is filed “within 3 years from the time the return was filed,” ibid., then the taxpayer is entitled to a refund of “the portion of the tax paid within the 3 years immediately preceding the filing of the claim.” 26 U.S.C. § 6511 (b)(2)(A) (incorporating by reference 26 U.S.C. § 6511 (a)). If the claim is not filed within that 3-year period, then the taxpayer is entitled to a refund of only that “portion of the tax paid during the 2 years immediately preceding the filing of the claim.” 26 U.S.C. § 6511 (b)(2)(B) (incorporating by reference § 6511(a)).”
16 later decisions quote this exact passage · from the majority“[cjlaim for credit or refund of an overpayment of any tax imposed by this title in respect of which tax the taxpayer is required to file a return shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.”
12 later decisions quote this exact passage · from the dissent
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.