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← 76 TC 209 - Boulez v. Commissioner

Boulez v. Commissioner’s Empirical Analysis

1981

Citation profile

112
cited by 112 later decisions
June 2020
most recently cited

6 federal appellate · 1 district ·

How this case has been cited

Cited by 112 later decisions — most recently June 2020 · most notably Reynolds v. Commissioner (1988), Boulez v. Commissioner (1987)

6 federal appellate · 1 district ·

53019811990200020102020decided

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. § 7122

Relies on United States Accardi v. Shaughnessy · Commissioner of Internal Revenue v. South Texas Lumber Co · Botany Worsted Mills v. United States · Boske v. Comingore · Schuster v. Commissioner

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 112 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The doctrine of equitable estoppel is applied against the Government 'with the utmost caution and restraint.'”
    11 later decisions quote this exact passage
  2. “the level of detriment necessary to bring the instant case within the category of those 'rare instances' where respondent should be estopped.”
    2 later decisions quote this exact passage
  3. “in light of the clear reference to the limitations prescribed by sec. 301.7122-1, Proced. & Admin.Regs., set forth in Rev.Proc. 64-44, repetition of that language in subsequent revisions of Delegation Order No. 11 would have been superfluous.”
    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.