Groetzinger v. Commissioner’s Empirical Analysis
1977
Citation profile
5 federal appellate ·
How this case has been cited
Cited by 38 later decisions — most recently June 2011 · most notably Pesch v. Commissioner (1982), O'Bryant v. United States (1995)
5 federal appellate ·
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 Commissioner of Internal Revenue v. Court Holding Co · Commissioner v. Stern · Montano v. United States · Schuster v. Commissioner · Shomaker v. Commissioner
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“assessed, paid, and collected in the same manner and subject to the same provisions and limitations”
3 later decisions quote this exact passage“amount shown as the tax by the taxpayer upon his return”
3 later decisions quote this exact passage“(a) Refunds After Limitation Period. — Any portion of a tax imposed by this title, refund of which is erroneously made, within the meaning of section 6514, may be recovered by civil action brought in the name of the United States. (b) Refunds Otherwise Erroneous. — Any portion of a tax imposed by this title which has been erroneously refunded (if such refund would not be considered as erroneous under section 6514) may be recovered by civil action brought in the name of the United States. [[Image here]] (d) Periods of Limitation.— For periods of limitations on actions under this section, see section 6532(b).”
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.