Prussner v. United States’s Empirical Analysis
896 F.2d 218 · 1990
Citation profile
46 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 93 later decisions — most recently January 2020 · most notably United States v. Poff (1991), Farmer v. Haas (1993)
46 federal appellate · 2 district · 1 state decisions
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. § 2032A
Relies on United States v. Boyle · United States v. Locke · Green v. Bock Laundry MacHine Co. · Riley Inv Co v. Commissioner of Internal Revenue · Palmer v. City of Chicago
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 93 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“‘we owe no special deference to the Tax Court’s legal views'”
12 later decisions quote this exact passage · from the majority““[t]here is nothing about filing a recapture agreement or for that matter a notice of election [on the tax return]. All that is required (in marked contrast to the Treasury regulation defining valid election for purposes of section 2032A) is the making of an election on the estate tax return — that is, the marking of the box for the election. The taxpayer who checks the box — that was done here— and provides substantially all the information that the return requires with respect to the election is home free.””
5 later decisions quote this exact passage · from the majority“provided substantially all the information with respect to such election required on such return of tax.”
3 later decisions 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.