544 F. Supp. 89 - Perlowin v. Sassi’s Empirical Analysis
1982
Citation profile
2 federal appellate ·
Relationships
Applies 26 U.S.C. § 6213 · 26 U.S.C. § 6331 · 26 U.S.C. § 6851 · 26 U.S.C. § 6861 · 26 U.S.C. § 7421 · 26 U.S.C. § 7428 · 26 U.S.C. § 7429 · 28 U.S.C. § 2201
Relies on Simon v. Eastern Kentucky Welfare Rights Organization · Bob Jones University v. Simon · Alexander v. "Americans United" Inc. · Laing v. United States · Eastern Kentucky Welfare Rights Organization v. Simon
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.
“a taxpayer who has been subjected to a termination assessment to contest the ultimate issue of his tax liability in the Tax Court in the same manner as is provided with respect to a taxpayer who has been subjected to a jeopardy assessment.”
1 later decision quote this exact passagee.g. Perlowin v. Sassi“Notwithstanding the provisions of section 7421(a), the making of such assessment or the beginning of such proceedings or levy during the time such prohibition is in force may be enjoined by a proceeding in the proper court.”
1 later decision quote this exact passagee.g. Perlowin v. Sassi“Congress was motivated by the same concerns which had prompted the Supreme Court to import the jeopardy termination safeguards into the termination assessment context.”
1 later decision quote this exact passagee.g. Perlowin v. Sassi
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.