Zinniel v. Commissioner’s Empirical Analysis
1989
Citation profile
27 federal appellate · 1 district ·
How this case has been cited
Cited by 73 later decisions — most recently March 2009 · most notably Powers v. Commissioner (1993), Rickel v. Commissioner (1990)
27 federal appellate · 1 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. § 1362 · 26 U.S.C. § 1372 · 26 U.S.C. § 7430 · 28 U.S.C. § 2412
Relies on Pierce v. Underwood · Miller v. Fenton · Morgan v. United States · FW/PBS, Inc. v. City of Dallas · Robnett 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 73 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“on the reasons given by that court for its determination that the Commissioner's position was not unreasonable.”
2 later decisions quote this exact passage · from the majority“incomplete directions with respect to the manner in which [compliance with statute was] to be made”
1 later decision quote this exact passage · from the majority“substantially prevailed with respect to the amount in controversy”
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.