Mills v. Garlow’s Empirical Analysis
1989
Citation profile
34 state decisions
How this case has been cited
Cited by 35 later decisions — most recently August 2023 · most notably 9 Cal. 4th 606 - International Engine Parts, Inc. v. Feddersen & Co. (1995), 593 So. 2d 351 - Harvey v. Dixie Graphics, Inc. (1992)
34 state decisions — followed in 11 states
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. § 1031 · 26 U.S.C. § 6212 · 26 U.S.C. § 6213 · 26 U.S.C. § 6501
Relies on Atlantic Richfield Co. v. Newman Oil Co. · Atkins v. Crosland · Leonhart v. Atkinson · Feldman v. Granger · Duke v. Housen
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“at the time of the statutory notice of deficiency or, in the alternative, at the equivalent time of taxpayer agreement with the IRS, precluding the otherwise required notice.”
3 later decisions quote this exact passage“(a) A cause of action arising from an act, error or omission in the rendering of licensed or certified professional or health care services shall be brought within the greater of the following times: (i) Within two (2) years of the date of the alleged act, error or omission, except that a cause of action may be instituted not more than two (2) years after discovery of the alleged act, error or omission, if the claimant can establish that the alleged act, error or omission was: (A) Not reasonably discoverable within a two (2) year period; or (B) The claimant failed to discover the alleged act, error or omission within the two (2) year period despite the exercise of due diligence.”
2 later decisions quote this exact passage“We anticipate that this approach would also comport with the response of the average taxpayer to an examiner's proposed adjustments. The first step by such a taxpayer, as in the instant case, is likely to be the contacting of the accountant for assistance in sorting out his tax difficulties with the IRS. This effort would be frustrated if the taxpayer was required to immediately file a lawsuit against the accountant.”
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.