Guthrie’s Empirical Analysis
Citation profile
8 federal appellate · 13 district · 4 state decisions
How this case has been cited
Cited by 62 later decisions — most recently January 2016 · most notably Davis v. Commissioner (2000), Wiley v. United States (1994)
8 federal appellate · 13 district · 4 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. § 6212 · 26 U.S.C. § 6213 · 26 U.S.C. § 6303 · 26 U.S.C. § 6321 (Federal Tax Lien Act of 1966) · 26 U.S.C. § 6322 · 26 U.S.C. § 6331
Relies on United States v. Dalm · Hughes · Elias v. Wh Connett · Lonsdale v. United States · Pasternak v. Lear Petroleum Exploration, Inc.
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 62 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Certificates of Assessments and Payments are 'routinely used to prove that tax assessment has in fact been made.' They are 'presumptive proof of a valid assessment.'”
3 later decisions quote this exact passage · from the majority“'that the evidence supporting a [party's] allegation is in the hands of the [opposing party] is insufficient to justify a denial of a motion for summary judgment under Rule 56(f).'”
2 later decisions quote this exact passage · from the majority“if mailed to the taxpayer at his last known address.”
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.