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← 669 F.3d 1333 - In re United States

In re United States’s Empirical Analysis

669 F.3d 1333 · 2012

Citation profile

8
cited by 8 later decisions
April 2017
most recently cited

3 federal appellate ·

Relationships

Applies 26 U.S.C. § 4681 · 26 U.S.C. § 6103 · 28 U.S.C. § 1651

Relies on Bailey v. United States · Russello v. United States · United States v. Menasche · Cheney v. United States District Court for District of Columbia · Mohawk Industries, Inc. v. Carpenter

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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “(4) Disclosure in judicial and administrative tax proceedings. — A return or return information may be disclosed in a Federal or State judicial or administrative proceeding pertaining to tax administration, but only— (B) if the treatment of an item reflected on such return is directly related to the resolution of an issue in the proceeding!.]”
    1 later decision quote this exact passage · from the majority
  2. “return or return information directly relates to a transactional relationship between a person who is a party to the proceeding and the taxpayer which directly affects the resolution of an issue in the proceeding.”
    1 later decision quote this exact passage · from the majority
  3. “directly related to the resolution of an issue in the proceeding.”
    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.