Collins v. Commissioner’s Empirical Analysis
1974
Citation profile
How this case has been cited
Cited by 36 later decisions — most recently June 2020 · most notably Capitol Fed. Sav. & Loan Ass'n v. Commissioner (1991), Casanova Co. v. Commissioner (1986)
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. § 170
Relies on United States v. Powell · Brotherhood of Railway & Steamship Clerks v. Florida East Coast Railway Co. · Baltimore & Ohio Railroad v. Boston & Maine Railroad · Luhring v. Glotzbach · De Masters v. Arend
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.
“failure to reopen would be a serious administrative omission.”
2 later decisions quote this exact passage“(b) Restrictions on Examination of Taxpayer. — No taxpayer shall be subjected to unnecessary examination or investigations, and only one inspection of a taxpayer’s books of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary or his delegate, after investigation, notifies the taxpayer in writing that an additional inspection is necessary.”
1 later decision quote this exact passagee.g. Kolom v. Comm'r“The Internal Revenue Service will not reopen any case closed”
1 later decision quote this exact passage
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.