Elias v. Wh Connett’s Empirical Analysis
908 F.2d 521 · 1990
Citation profile
129 federal appellate · 12 district · 1 state decisions
How this case has been cited
Cited by 228 later decisions — most recently June 2020 · most notably Hughes, Craig v. Comm'r (2002)
129 federal appellate · 12 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. § 6212 · 26 U.S.C. § 6213 · 26 U.S.C. § 6303 · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6334 · 26 U.S.C. § 6672 · 26 U.S.C. § 6682 · 26 U.S.C. § 7421
Relies on Conley v. Gibson · Sampson v. Murray · Enochs v. Williams Packing & Navigation Co. · Bob Jones University v. Simon · Atlas Roofing Co. v. Occupational Safety & Health Review Commission
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 228 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The form on which a notice of assessment and demand for payment is made is irrelevant as long as it provides the taxpayer with all the information required under 26 U.S.C. section 6303 (a) .”
25 later decisions quote this exact passage · from the majority“[t]he United States may be named a party in any civil action or suit in any district court ... to quiet title to ... real or personal property on which the United States has or claims a mortgage or other lien.”
24 later decisions quote this exact passage · from the majority“suit for the purpose of restraining the assessment or collection of any tax....”
24 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.