Stonecipher v. Bray’s Empirical Analysis
653 F.2d 398 · 1981
Citation profile
50 federal appellate · 17 district · 2 state decisions
How this case has been cited
Cited by 105 later decisions — most recently February 2014 · most notably King v. State of California D M (1986), San Bernardino Physicians' Services Medical Group, Inc. v. County of San Bernardino (1987)
50 federal appellate · 17 district · 2 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 26 U.S.C. § 7421 · 26 U.S.C. § 7422
Relies on Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics · Enochs v. Williams Packing & Navigation Co. · Phillips v. Commissioner · Bob Jones University v. Simon · 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 105 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[D]ue process rights are adequately protected by the statutory scheme which allows [a taxpayer] to contest his tax liability in the Tax Court prior to paying the disputed tax or to sue for a refund in federal district court or in the Court of Claims.”
7 later decisions quote this exact passage · from the majority“(a) Tax. — Except as provided in sections 6212(a) and (e), 6213(a) [where no deficiency notice has been given], 6672(b) [failure to collect withholding tax and pay over to IRS], 6694(c) [preparers of tax returns], 7426(a) and (b)(1) [persons other than the taxpayer], and 7429(b) [unreasonable jeopardy assessments], 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.”
4 later decisions quote this exact passage · from the majority“(5) Computation of withholding, (i) Until receipt of written notice from the Internal Revenue Service that a certificate, a copy of which was submitted under this section, is defective, that certificate is effective and the employer shall withhold on the basis of the statements made in that certificate, unless that certificate must be disregarded under the provisions of paragraph (g)(5)(vi) of this section. (ii) The Internal Revenue Service may find that a copy of a withholding exemption certificate submitted contains a materially incorrect statement or it may determine, after written request to the employee for verification of the statements on the certificate, that it lacks sufficient information to determine if the certificate is correct. If the Internal Revenue Service so finds or determines and notifies the employer in writing that the certificate is defective, the employer shall then consider the certificate to be defective for purposes of computing amounts of withholding. (iii) If the Internal Revenue Service notifies the employer that the certificate is defective, the Internal Revenue Service will, based upon its findings, advise the employer that the employee is not entitled to claim a status exempting the employee from withholding or is not entitled to claim a total number of withholding exemptions in excess of a number specified by the Internal Revenue Service in the notice, or both. The Internal Revenue Service will also specify the Internal Revenue Service office”
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.