Rowley v. United States’s Empirical Analysis
76 F.3d 796 · 1996
Citation profile
19 federal appellate ·
Relationships
Applies 26 U.S.C. § 6103 · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6331 · 26 U.S.C. § 7431
Relies on Calder v. Job · Perez v. Jones · Rogers v. United States · Board of Education v. Illinois State Board of Education · Sims v. Memphis Processors, Inc.
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“if the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.”
4 later decisions quote this exact passage · from the majority“[T]he approach we adopt today strikes the proper balance between a taxpayer's reasonable expectation of privacy and the government's legitimate interest in disclosing tax return information to the extent necessary for tax administration functions.”
1 later decision quote this exact passage · from the majoritye.g. Johnson v. Sawyer“the recording of a federal tax lien ... is designed to provide public notice and is thus qualitatively different from disclosures made in judicial proceedings, which are only incidentally made public”
1 later decision quote this exact passage · from the majoritye.g. Johnson v. Sawyer
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.