Ewing v. United States’s Empirical Analysis
914 F.2d 499 · 1990
Citation profile
34 federal appellate · 6 district · 1 state decisions
How this case has been cited
Cited by 69 later decisions — most recently May 2019 · most notably Callaway v. Commissioner (2000), Philadelphia Reading Corporation v. United States (1991)
34 federal appellate · 6 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. § 6401 · 26 U.S.C. § 6402 · 26 U.S.C. § 6501 · 26 U.S.C. § 6511 · 26 U.S.C. § 7121
Relies on United States v. Dalm · Goss v. Board of Education · Rosenman v. United States · Lewyt Corporation v. Commissioner of Internal Revenue · Ritter 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 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“for the purposes of deciding whether a remittance was a payment of tax, formal assessment is only one factor to be considered.”
4 later decisions quote this exact passage · from the majority“not that of weighing equities, but of determining technical application of the law [consistent] . . . with the well established view that tax laws are technical and, for the most part, are to be accordingly interpreted.”
3 later decisions quote this exact passage · from the majority““overpayment” includes that part of the amount of the payment of any internal revenue tax which is assessed or collected after the expiration of the period of limitation properly applicable thereto.”
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.