Seneca, Ltd. v. Commissioner’s Empirical Analysis
1989
Citation profile
3 federal appellate · 1 state decisions
How this case has been cited
Cited by 23 later decisions — most recently February 2016
3 federal appellate · 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. § 6223
Relies on Computer Programs Lambda, Ltd. v. Commissioner · Clovis I v. Commissioner · Chomp Assoc. v. Commissioner · Computer Programs Lambda, Ltd. v. Commissioner · Transpac Drilling Venture 1982-22 v. Commissioner
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[any injury that petitioners suffer as a result of filing their petition out of time was caused by their own inaction and was not caused by respondent's conduct.”
1 later decision quote this exact passage“the absence of a tax matters partner for Seneca had no adverse effect on petitioners' rights to notice and hearing.”
1 later decision quote this exact passage“Notice of Final Partnership Administrative Adjustment”
1 later decision quote this exact passage
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.