Miller v. United States’s Empirical Analysis
949 F.2d 708 · 1991
Citation profile
6 federal appellate · 3 district · 1 state decisions
Relationships
Applies 26 U.S.C. § 6511 · 26 U.S.C. § 7422
Relies on Automobile Club of Mich. v. Commissioner · Chase Securities Corp. v. Donaldson · Abel v. United States · Angelus Milling Co. v. Commissioner · Florida Citrus Exposition, Inc. v. Hungerford Construction Co.
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“within 3 years from the time the return was filed”
3 later decisions quote this exact passage · from the majority“[T]he Government is not bound by the unauthorized or incorrect statements of its agents.”
2 later decisions quote this exact passage · from the majority“Under relevant ease law, it is clear that neither the government, nor a government agency such as the IRS, can be equitably estopped from asserting its legal rights because of the actions of an agent ... Furthermore, courts expressly have prohibited the application of the doctrine of equitable estoppel in cases involving the IRS.”
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.