Stocker v. United States’s Empirical Analysis
705 F.3d 225 · 2013
Citation profile
Relationships
Applies 26 U.S.C. § 6511 · 26 U.S.C. § 7422 · 26 U.S.C. § 7502 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on United States v. Testan · United States v. Dalm · Anderson v. United States · Miller v. United States · Deutsch 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] "party seeking an adverse inference instruction based on the destruction of evidence must establish (1) that the party having control over the evidence had an obligation to preserve it at the time it was destroyed; (2) that the records were destroyed with a culpable state of mind; and (3) that the destroyed evidence was relevant to [a] party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense."”
1 later decision quote this exact passage · from the majority“failure to produce evidence that would satisfy either of [ § 7502 ]'s two specified exceptions [was] fatal to their suit for a refund.”
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.