United States v. Will’s Empirical Analysis
671 F.2d 963 · 1982
Citation profile
51 federal appellate · 7 district ·
How this case has been cited
Cited by 110 later decisions — most recently June 2020 · most notably Boulez v. Commissioner (1987), Equal Employment Opportunity Commission v. K-Mart Corp. (1982)
51 federal appellate · 7 district ·
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
Relies on United States v. Powell · Donaldson v. United States · United States v. National Bank · Ellington v. Blumstein · United States v. Garden State National Bank
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 110 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he use of discovery devices in summons enforcement proceedings should be limited to those cases where the taxpayer makes a preliminary and substantial demonstration of abuse.”
4 later decisions quote this exact passage · from the majority“adopted solely for the internal administration of the IRS, rather than for the protection of the taxpayer, does not confer any rights upon the taxpayer”
3 later decisions quote this exact passage · from the majority“Such an abuse would take place if the summons had been issued for an improper purpose, such as to harass the taxpayer or to put pressure on him to settle a collateral dispute, or for any other purpose reflecting on the good faith of the particular investigation.”
2 later decisions 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.