Schiff v. United States’s Empirical Analysis
919 F.2d 830 · 1990
Citation profile
20 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 73 later decisions — most recently September 2019 · most notably Geiselman v. United States (1992), In Re: Jerasimos Papapanayotou, Esq., Jerasimos Papapanayotou, Esq. v. Jeffrey Sapir, Esq., as Chapter 7 Trustee (2000)
20 federal appellate · 3 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. § 6020 · 26 U.S.C. § 6201 · 26 U.S.C. § 6303 · 26 U.S.C. § 6501
Relies on Pelaes v. United States · United States v. Radio Television News Directors Ass'n · Brushaber v. Union Pacific Railroad · Ohio State Board of Education v. Reed · Thompson v. Thompson
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 73 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Income Tax Examination Changes, " precludes its use to assess petitioner's tax liability simply because petitioner did not file an original return. J.A. at 35 (emphasis added). We have held that "when a taxpayer does not file a tax return, it is as if he filed a return showing a zero amount for the purposes of assessing a deficiency.”
5 later decisions quote this exact passage · from the majority“To make the sanction effective terms of their noncompliance with an unequivocal order from this court, Allustiartes never sought any relief from their adjudicated obligation, either on the now-suggested ground or on any other basis--like any other scofflaw, they simply ignored the obligation. and thereby protect the processes of a court from abuse, a litigant against whom Rule 38 sanctions have been imposed must comply with those sanctions before being permitted to pursue new matters in that court.”
2 later decisions quote this exact passage · from the majoritye.g. Allustiarte Allustiarte Allustiarte · In Re: Ben Allustiarte & Linda Allustiarte, Debtors Ben W. Allustiarte Linda M. Allustiarte Gregory R. Allustiarte Debtors-Appellants v. W. Austin Cooper, Trustee-Appellee in Re: Ben Allustiarte & Linda Allustiarte, Debtors Ben W. Allustiarte Linda M. Allustiarte Gregory R. Allustiarte Debtors-Appellants v. W. Austin Cooper Office of the U.S. Trustee, Trustees-Appellees“is one of those highly unusual instances which permit the imposition of sanctions under Rule 38 because of a clear showing of bad faith”
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.