Russell v. United States’s Empirical Analysis
592 F.2d 1069 · 1979
Citation profile
19 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 50 later decisions — most recently January 2012 · most notably Naftel v. Commissioner (1985), Russell v. Commissioner (1982)
19 federal appellate · 2 district · 1 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 16 U.S.C. § 165 · 26 U.S.C. § 165 · 26 U.S.C. § 6512 · 26 U.S.C. § 6651 · 26 U.S.C. § 7422 · 26 U.S.C. § 7459
Relies on Commissioner v. Sunnen · Cromwell v. County of Sac · Flora v. United States · Schuster v. Commissioner · Sun Il Yoo v. Immigration & Naturalization Service
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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“jurisdiction to decide the entire gamut of possible issues”
8 later decisions quote this exact passage · from the majority“If the .Secretary has mailed to the taxpayer a notice of deficiency * * * and if the taxpayer files a petition with the Tax Court within the time prescribed in section 6213(a), no credit or refund of income tax for the same taxable year * * * in respect of which the Secretary has determined the deficiency shall be allowed or made and no suit by the taxpayer for the recovery of any part of the tax shall be instituted in any court * * * [With certain exceptions not applicable here.]”
2 later decisions quote this exact passage · from the majority“Income taxes are levied on an annual basis. Each year is the origin of a new liability and of a separate cause of action. Thus if a claim of liability or non-liability relating to a particular tax year is litigated, a judgment on the merits is res judicata as to any subsequent proceeding involving the same claim and the same tax year. * * *”
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.