Ryan v. United States’s Empirical Analysis
74 F.3d 1161 · 1996
Citation profile
3 federal appellate · 1 state decisions
How this case has been cited
Cited by 8 later decisions — most recently December 2019
3 federal appellate · 1 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. § 6103 · 26 U.S.C. § 7431
Relies on South Central Enterprises, Inc. v. Farrington · Modjeski & Masters, Applicant, V · Stokwitz v. United States · Childrey v. Bennett · Jackson 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]o be “return information” any information must first be “received by, recorded by, prepared by, furnished to, or collected by” the IRS. The plain language of the statute reveals that “return information” must be information which has somehow passed through, is directly from, or generated by the IRS. In' sum, section 6103 requires that the source of the disclosed information must have been the IRS in order for there to be a violation of the general prohibition against the disclosure of return information.”
2 later decisions quote this exact passage“The district court concluded that section 6103, and hence section 7431, were directed 'at those government officers and employees who obtained returns and return information as a result of these materials being filed by or on behalf of the taxpayer, or received by, furnished to, or collected by the Secretary.' We agree.”
1 later decision quote this exact passage“confines it to information that has passed through the IRS.”
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.