Does 1977 1978’s Empirical Analysis

Citation profile

1 district ·

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. “A 'John Doe' summons is, in essence, a direction to a third party to surrender information concerning taxpayers whose identity is currently unknown to the IRS.”

   2 later decisions quote this exact passage · from the majority
   e.g. United States Court of Appeals, Ninth Circuit · United States Court of Appeals, Second Circuit

2. “under 7609(f)(2), that audits of tax returns of members of other barter exchanges had revealed a high incidence of improper reporting. 14 In Columbus Trade Exchange, the district court declined to authorize the service of the John Doe summons on the barter exchange there involved, finding that the IRS had failed to meet the requirement of 7609(f)(2). In reversing, the Sixth Circuit held that the district court interpreted the statutory standard set forth in 26 U.S.C. § 7609 (f)”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Brigham Young University

3. “which operates as a clearing house for the exchange of goods and services, other than for cash, between members of the exchange. In each case the IRS sought to serve a John Doe summons on a named barter exchange to obtain the names of the exchange's members, and the IRS alleged as its”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Brigham Young University