Samuels, Kramer & Co. v. Commissioner’s Empirical Analysis
930 F.2d 975 · 1991
Citation profile
14 federal appellate · 2 district ·
How this case has been cited
Cited by 49 later decisions (1 by the Supreme Court) — most recently December 2023 · most notably Freytag v. Commissioner (1991), Tomka v. Seiler Corp. (1995)
14 federal appellate · 2 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 15 U.S.C. § 78D (§ 4 of the Securities Exchange Act of 1934) · 26 U.S.C. § 6621 · 26 U.S.C. § 6653 · 26 U.S.C. § 7441 · 26 U.S.C. § 7443 · 26 U.S.C. § 7443A · 26 U.S.C. § 7453 · 26 U.S.C. § 7456
Relies on Mathews v. Eldridge · Boykin v. Alabama · Buckley v. Valeo · Northern Pipeline Construction Co. v. Marathon Pipe Line Co. · United States v. Testan
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a rule of statutory construction that provides that when general words follow the enumeration of particular classes, the general words should be construed as applying only to things of the same general class as those enumerated.”
3 later decisions quote this exact passage · from the dissent“Although the ultimate decisional authority in cases under section 7443A(b)(4) rests with the Tax Court judges, the special trial judges do exercise a great deal of authority in such cases. The special trial judges are more than mere aids to the judges of the Tax Court. They take testimony, conduct trials, rule on the admissibility of evidence, and have the power to enforce compliance with discovery orders. Contrary to the contentions of the Commissioner, the degree of authority exercised by special trial judges is "significant.” They exercise a great deal of discretion and perform important functions, characteristics that we find to be inconsistent with the classifications of "lesser functionary” or mere employee.”
2 later decisions quote this exact passage · from the majority“[A]ny appointee exercising significant authority pursuant to the laws of the United States is an 'Officer of the United States,' and must, therefore, be appointed in the manner prescribed by § 2, cl. 2, of [Art. II].”
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.