Smith v. United States’s Empirical Analysis
921 F.2d 136 · 1990
Citation profile
3 federal appellate · 3 district ·
How this case has been cited
Cited by 17 later decisions — most recently August 2024
3 federal appellate · 3 district ·
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 11 U.S.C. § 505 · 26 U.S.C. § 6672 · 26 U.S.C. § 7422
Relies on United States v. Munsingwear, Inc. · North Carolina v. Rice · Smith v. United States (In Re Smith)
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a)(l)Except as provided in paragraph (2) of this subsection, the court may determine the amount or legality of any tax, any fine or penalty relating to & tax,'or any addition to tax, whether or not previously assessed, whether or not paid, and whether or not contested before and adjudicated by a-judicial or administrative tribunal of competent jurisdiction. (2) The court may not so determine— (B) any right of the estate to a tax refund, before the earlier of - (i) 120 days, after the trustee properly requests such refund from the governmental unit from which such re fund is claimed; or (ii) a determination by such governmental unit of such request.”
1 later decision quote this exact passage · from the majority“sit to decide only live controversies, cases that will have a real, practical effect.”
1 later decision quote this exact passage · from the majority“there [was] no longer any real controversy.”
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.