Koss v. United States’s Empirical Analysis
69 F.3d 705 · 1995
Citation profile
6 federal appellate · 4 district · 1 state decisions
How this case has been cited
Cited by 22 later decisions — most recently August 2016
6 federal appellate · 4 district · 1 state decisions
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
Applies 26 U.S.C. § 1016 (Retirement-Straight Line Adjustment Act of 1958) · 26 U.S.C. § 1311 · 26 U.S.C. § 1312 · 26 U.S.C. § 1313 · 26 U.S.C. § 6511 · 26 U.S.C. § 6512 · 26 U.S.C. § 7422 · 28 U.S.C. § 1291
Relies on United States v. Testan · United States v. Sherwood · Flora v. United States · United States v. Dalm · In re Disbarment of Gonzales
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Effect of petition to Tax Court. — If the Secretary- has mailed to the taxpayer a notice of deficiency under section 6212(a) (relating to deficiencies of income, estate, gift, and certain excise taxes) and if the taxpayer files a petition with the Tax Court within the time prescribed in section 6213(a) ..., no credit or.refund of income tax for the same taxable year ... in respect of which the Secretary has determined the deficiency shall be allowed or made and no suit by the taxpayer for the recovery of any part of the tax shall be instituted in any court....”
1 later decision quote this exact passage · from the majority“If the claim for credit or refund relates to an overpayment attributable to a net operating loss carryback ..., in lieu of the 3-year period of limitation prescribed in subsection (a), the period shall be that period which ends 3 .years after the time prescribed by law for filing the return (including extensions thereof) for the taxable year of the net operating loss----”
1 later decision quote this exact passage · from the majority“[a]ny civil action against the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, or any penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected under the internal-revenue laws.”
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.