Shannon v. United States’s Empirical Analysis
521 F.2d 56 · 1975
Citation profile
18 federal appellate · 6 district ·
How this case has been cited
Cited by 36 later decisions — most recently May 2011 · most notably Elias v. Wh Connett (1990), Flores v. United States (1977)
18 federal appellate · 6 district ·
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. § 6861 · 26 U.S.C. § 7421 · 26 U.S.C. § 7426 · 28 U.S.C. § 1292 · 28 U.S.C. § 1340 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Enochs v. Williams Packing & Navigation Co. · Phillips v. Commissioner · Bob Jones University v. Simon · Miller v. Standard Nut Margarine Co. · Phillips v. Commissioner
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Tax. — Except as provided in sections 6015(e), 6212(a) and (c), 6213(a), 6225(b), 6246(b), 6330(e)(1), 6331(i), 6672(c), 6694(c), 7426(a) and (b)(1), 7429(b), and 7436, no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed. (b) Liability of transferee or fiduciary. — No suit shall be maintained in any court for the purpose of restraining the assessment or collection (pursuant to the provisions of chapter 71) of— (1) the amount of the liability, at law or in equity, of a transferee of property of a taxpayer in respect of any internal revenue tax ...”
4 later decisions quote this exact passage · from the majority“[w]ithin 90 days ... after the notice of deficiency authorized in section 6212 is mailed ... the taxpayer may file a petition with the Tax Court for a redetermination of the deficiency.”
2 later decisions quote this exact passage · from the majority“other than the person against whom is assessed the tax out of which such levy arose,”
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.