Testimony of Arthur Andersen Co Wheatley’s Empirical Analysis
1987
Citation profile
4 federal appellate · 3 district ·
How this case has been cited
Cited by 15 later decisions — most recently December 2015
4 federal appellate · 3 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. § 7430
Relies on United States v. Powell · Keasler v. United States · United States v. Samuels, Kramer & Co. · 584 F. Supp. 872 - Kaufman v. Egger · Berks 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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) whether the government used the costs and expenses of litigation against its position to extract concessions from the taxpayer that were not justified under the circumstances of the case, (2) whether the government pursued the litigation against the taxpayer for purposes of harassment or embarrassment, or out of political motivation, and (3) such other factors as the court finds relevant.”
1 later decision quote this exact passage · from the majority“deter abusive actions and overreaching by the Internal Revenue Service and ... enable individual taxpayers to vindicate their rights regardless of their economic circumstances.”
1 later decision quote this exact passage · from the majority“all the facts and circumstances surrounding the proceeding.”
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.