United States v. Samuels, Kramer & Co.’s Empirical Analysis
712 F.2d 1342 · 1983
Citation profile
36 federal appellate · 6 district ·
How this case has been cited
Cited by 60 later decisions — most recently May 2023 · most notably Ponsford v. United States (1985), United States v. Abrahams (1990)
36 federal appellate · 6 district ·
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 United States v. Powell · Northern Pipeline Construction Co. v. Marathon Pipe Line Co. · United States v. National Bank · Ohio State Board of Education v. Reed · Akers v. United States
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“must show that the investigation will be conducted pursuant to a legitimate purpose, that the inquiry may be relevant to the purpose, that the information sought is not already within the Commissioner [of the IRS’s] possession, and that the administrative steps required by the [IRS] Code have been followed [with respect to issuance and service of the summons].”
3 later decisions quote this exact passage · from the majority“The IRS is free to serve, without prior judicial approval, a direct summons on any person if the summons is necessary to facilitate the investigation of that person's tax liability.”
2 later decisions quote this exact passage · from the majority“its use of the summons is 'in good-faith pursuit' of the purposes authorized by Congress,”
2 later decisions 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.