Bancsi v. Pennington’s Empirical Analysis
1992
Citation profile
1
cited by 1 later decisions
January 1997
most recently cited
1 district ·
Relationships
Applies 26 U.S.C. § 7609
Relies on United States v. Testan · United States v. Sherwood · 636 F. Supp. 93 - Church of Human Potential, Inc. v. Vorsky
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 1 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Generally, § 7609(a) requires the IRS to provide notice to the person whose records have been summoned. However, no notice need be provided if the summons is issued to aid the collection of a tax liability which was previously assessed or adjudged. § 7609(c)(2)(B)(ii). Since the IRS need not provide notice of a summons issued in aid of collection, no person has a right to move to quash such a summons. “Essentially, a District Court lacks jurisdiction to entertain a petition to quash a collection summons.” Church of Human Potential, Inc. v. Vorsky, 636 F.Supp. 93, 94 (D.N.J.1986).”
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.