Eagan v. United States’s Empirical Analysis
80 F.3d 13 · 1996
Citation profile
10 federal appellate · 2 district ·
How this case has been cited
Cited by 20 later decisions — most recently September 2015
10 federal appellate · 2 district ·
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. § 3101 (Federal Insurance Contributions Act) · 26 U.S.C. § 3121 (Federal Insurance Contributions Act) · 26 U.S.C. § 401 (Self-Employed Individuals Tax Retirement Act of 1962) · 26 U.S.C. § 402 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6501 · 26 U.S.C. § 72
Relies on Rita v. United States · Breininger v. Sheet Metal Workers International Ass'n Local Union No. 6 · Herrington v. Commissioner · Levy v. Federal Deposit Insurance · Beltzer 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) A representation or report by the taxpayer; (2) on which the Commission[er] has relied; and (3) an attempt by the taxpayer after the statute of limitations has run to change the previous representation or to recharacterize the situation in such a way as to harm the Commissioner. If this test is met, the Commissioner may act as if the previous representation, on which he relied, continued to be true, even if it is not. The taxpayer is estopped to assert the contrary.”
2 later decisions 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.