Calcutt v. Commissioner’s Empirical Analysis
1988
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 27 later decisions — most recently October 2019 · most notably Liberty Mutual Insurance v. FAG Bearings Corp. (2003), Thurner v. Comm'r (2003)
1 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. § 7456
Relies on Bonner v. City of Prichard · Montana v. United States · Commissioner v. Sunnen · Stern v. Board of Levee Commissioners · Tait v. Western Maryland Railway Co.
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Collateral estoppel generally prevents parties and their privies from relitigating issues previously decided by a court of competent jurisdiction relating to a different tax year, or involving a new cause of action.”
1 later decision quote this exact passage · from the majority“evidence which, by due diligence, could have been produced in the first proceeding is considered to have been available at the first proceeding”
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.