Ferrel v. Brown’s Empirical Analysis

Citation profile

5 federal appellate · 3 district ·

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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[i]f, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally, or by reason of negligence disregards any provision of this title ... such taxpayer may bring a civil action for damages against the United States in a district court of the United States.”

   2 later decisions quote this exact passage
   e.g. 82 F. Supp. 2d 1134 - Soghomonian v. United States · 525 F. Supp. 2d 55 - Ludvigson v. United States

2. “If, in connection with any collection of Federal tax with respect to a taxpayer, any officer or employee of the Internal Revenue Service recklessly or intentionally disregards any provision of this title, or any regulation promulgated under this title, such taxpayer may bring a civil action for damages against the United States in a district court of the United States....”

   1 later decision quote this exact passage
   e.g. Wittmann v. United States

3. “[t]he district court shall have jurisdiction to grant only such of the following forms of relief as may be appropriate in the circumstances,”

   1 later decision quote this exact passage
   e.g. Allied/Royal Parking L.P. v. United States