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← 676 F.3d 1129 - Tucker v. Commissioner

Tucker v. Commissioner’s Empirical Analysis

676 F.3d 1129 · 2012

Citation profile

33
cited by 33 later decisions
May 2020
most recently cited

6 federal appellate · 1 district ·

Relationships

Applies 26 U.S.C. § 6320 · 26 U.S.C. § 7121 · 26 U.S.C. § 7122 · 26 U.S.C. § 7803 · 26 U.S.C. § 7804

Relies on Buckley v. Valeo · Securities and Exchange Commission v. Chenery Corporation Same · Freytag v. Commissioner · PDK Laboratories Inc. v. United States Drug Enforcement Administration · Free Enterprise Fund v. Public Company Accounting Oversight Bd.

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

  1. “The main criteria for drawing the line between inferior Officers and employees not covered by the clause are (1) the significance of the matters resolved by the officials, (2) the discretion they exercise in reaching their decisions, and (3) the finality of those decisions.”
    1 later decision quote this exact passage
  2. “the absence of any authority to render final decisions [was] fatal to the claim that the [persons] at issue were Officers rather than employees”
    1 later decision quote this exact passage
  3. “been sold, gifted, transferred, or spent on non-priority items or debts and are no longer available to pay the tax liability.”
    1 later decision quote this exact passage

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.