Boulez v. Commissioner’s Empirical Analysis
1987
Citation profile
24 federal appellate · 6 district ·
How this case has been cited
Cited by 133 later decisions — most recently June 2020 · most notably Reynolds v. Commissioner (1988), Woods v. Commissioner (1989)
24 federal appellate · 6 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.
Appellate journey
reviewedthe decision below (from District of Columbia District Court)
Relationships
Applies 26 U.S.C. § 7121 · 26 U.S.C. § 7122 · 26 U.S.C. § 7805 · 5 U.S.C. § 301
Relies on Federal Crop Ins Corporation v. Merrill · Commissioner of Internal Revenue v. South Texas Lumber Co · Schweiker v. Hansen · United States v. Correll · Lombard v. Marcera
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 133 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Part 601 rules differ significantly from the [Treasury] regulations.... Issued by the Commissioner, without need for approval by the Secretary, they serve merely as guidelines for conducting the internal affairs of the agency. The authority of the Commissioner to issue such rules derives from [ 5 U.S.C. § 301 ], As such, the Statement of Procedural Rules is held to be directory, not manda- . tory in nature.”
3 later decisions quote this exact passage · from the majority“[T]hose who deal with the government are charged with knowledge of applicable statutes and regulations.”
2 later decisions quote this exact passage · from the majoritye.g. Ostrom v. Comm'r · Farina v. Comm'r“the settled principle that 'Treasury regulations and interpretations long continued without substantial change, applying to unamended or substantially reenacted statutes, are deemed to have received congressional approval and have the effect of law.'”
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.