Little v. United States’s Empirical Analysis
794 F.2d 484 · 1986
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 18 later decisions — most recently February 2002
9 federal appellate ·
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. § 7425 · 26 U.S.C. § 7805 · 28 U.S.C. § 2410
Relies on Montana v. United States · Commissioner of Internal Revenue v. South Texas Lumber Co · Jizmejian v. United States · United States v. Correll · United States v. Cartwright
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“actually litigated and necessarily determined”
2 later decisions quote this exact passage · from the majority“Necessary inferences from the judgment, pleadings and evidence will be given preclusive effect. But if there is doubt, collateral estoppel will not be applied, especially if the previous decision could have been rationally grounded on an issue other than that which the defendant seeks to foreclose from consideration.”
1 later decision quote this exact passage · from the majority“'must introduce a record sufficient to reveal the controlling facts and pinpoint the exact issues litigated in the prior action.'”
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.