Kile v. Commissioner of Internal Revenue’s Empirical Analysis
1984
Citation profile
7 federal appellate · 3 district · 7 state decisions
How this case has been cited
Cited by 67 later decisions — most recently November 2014 · most notably Tweeddale v. Commissioner (1989), Sauers Nj 08404 v. Commissioner of Internal Revenue
7 federal appellate · 3 district · 7 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. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on In re Kauffman Mutual Fund Actions · Mackay v. Nesbett · Murzyn v. United States · Canron, Inc. v. Plasser American Corp. · United States v. First City National Bank of Houston
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The doors of this courthouse are of course open to good faith appeals of what are honestly thought to be errors of the lower courts. But we can no longer tolerate abuse of the judicial review process by irresponsible taxpayers who press stale and frivolous arguments, without hope of success on the merits, in order to delay or harass the collection of public revenues or for other nonworthy purposes. Rule 38 of the Federal Rules of Appellate Procedure provides that a Court of Appeals may award just damages and single or double costs for frivolous appeals____ This Court has recently awarded reasonable attorney’s fees and double costs to the government for a frivolous tax appeal. Other circuits, recognizing the waste of limited judicial and administrative resources that such groundless actions have occasioned, have awarded damages or other extraordinary costs in cases such as these.”
10 later decisions quote this exact passage · from the majority“given the universal and longstanding rejection of this argument.”
2 later decisions quote this exact passage · from the majority“yet another disturbing example of a patently frivolous appeal filed by abusers of the tax system merely to delay and harass the collection of public revenues”
1 later decision quote this exact passage · from the majoritye.g. Hyde v. Commissioner
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.