Webb v. United States’s Empirical Analysis
66 F.3d 691 · 1995
Citation profile
19 federal appellate · 3 district · 4 state decisions
How this case has been cited
Cited by 45 later decisions (1 by the Supreme Court) — most recently May 2023 · most notably United States v. Brockamp (1997), Hedges v. United States (2005)
19 federal appellate · 3 district · 4 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 15 U.S.C. § 78I (§ 9 of the Securities Exchange Act of 1934) · 26 U.S.C. § 6511 · 26 U.S.C. § 7422 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 5 U.S.C. § 7703
Relies on Zipes v. Trans World Airlines, Inc. · Irwin v. Department of Veterans Affairs · United States v. Kubrick · M'Culloch v. State of Maryland · Lampf, Pleva, Lipkind, Prupis & Petigrow v. Gilbertson
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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Claim for credit or refund of an overpayment of any tax imposed by this title in respect of which the tax the taxpayer is required to file a return shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.”
2 later decisions quote this exact passage · from the majority“If the claim was filed by the taxpayer during the 3-year period . . . the amount of the credit or refund shall not exceed the portion of the tax paid within the period, immediately preceding the filing of the claim, equal to 3 years plus the period of any extension of time for filing the return . . . . '' —§6511(b)(2)(A). And 12”
2 later decisions quote this exact passage · from the majority“a procedural device that operates as a defense to limit the remedy available from an existing cause of action,”
2 later decisions quote this exact passage · from the dissent
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.