Petrie v. Commissioner’s Empirical Analysis
1988
Citation profile
3 district · 1 state decisions
Relationships
Applies 26 U.S.C. § 6212 · 26 U.S.C. § 6213 · 26 U.S.C. § 6303 · 26 U.S.C. § 6334 · 26 U.S.C. § 6501 · 26 U.S.C. § 6503 · 26 U.S.C. § 6672 · 26 U.S.C. § 6694
Relies on Mathews v. Eldridge · Haines v. Kerner · Fuentes v. Shevin · Gerstein v. Pugh · Sampson v. Murray
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Except as provided in section!] ... 7426(a) ... no suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.”
1 later decision quote this exact passage · from the majority“[t]he financial difficulties which plaintiff may encounter pending a refund suit do not establish irreparable harm”
1 later decision quote this exact passage · from the majority“Statement of Tax Due on Federal Tax Return” that is sent pursuant to § 6303, which requires notice to taxpayers”
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.