Newton v. Pennington’s Empirical Analysis
1983
Citation profile
1 federal appellate · 3 state decisions
How this case has been cited
Cited by 16 later decisions — most recently September 2010
1 federal appellate · 3 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. § 7609
Relies on Hickman v. Taylor · Bonner v. City of Prichard · Upjohn Company v. United States · United States v. Powell · Couch 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Supreme Court in United States v. Powell, 379 U.S. 48 , 85 S.Ct. 248 , 13 L.Ed.2d 112 (1964) defined the minimal showing that the IRS must make when seeking an order to enforce its summons. Id. at 57-58 , 85 S.Ct. at 255 . It must show that the investigation will be conducted pursuant to a legitimate purpose, that the inquiry may be relevant to that purpose, that the information sought is not already within the Commission’s possession, and that the administrative steps required by the Code have been followed.”
1 later decision quote this exact passage · from the majority“show [1] that the investigation will be conducted pursuant to a legitimate purpose, [2] that the inquiry may be relevant to the purpose, [3] that the information sought is not already within the Commissioner’s possession, and [4] that the administrative steps required by the Code have been followed — in particular, that the ‘Secretary or his delegate,’ after investigation, has determined the further examination to be necessary and has notified the taxpayer in writing to that effect.”
1 later decision quote this exact passage · from the majority“[F]or example ... the attorney-client privilege and the attorney work product doctrine limit the scope of the IRS summons power.” Matter of Newton, 718 F.2d 1015, 1021 (11th Cir.1983). 9 .”
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.