Peck v. Commissioner’s Empirical Analysis
1988
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 120 later decisions — most recently April 2020 · most notably Meier v. Commissioner (1988), Peck v. Commissioner (1990)
2 federal appellate ·
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. § 482
Relies on Montana v. United States · Commissioner v. Sunnen · Amos v. Commissioner of Internal Revenue · Amos v. Commissioner · Evergreens v. Nunan
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 120 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“three-pronged rubric provided by the Supreme Court in the Montana case embodies a number of detailed tests developed by the courts to test the appropriateness of collateral estoppel in essentially factual contexts.”
3 later decisions quote this exact passage · from the majority“[t]he parties must actually have litigated the issues and the resolution of these issues must have been essential to the prior decision”
3 later decisions quote this exact passage · from the majority“Basically, collateral estoppel precludes parties (and their privies) from relitigating issues actually and necessarily litigated and decided in a final prior judgment by a court of competent jurisdiction.”
2 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.