Smith v. Brady’s Empirical Analysis
972 F.2d 1095 · 1992
Citation profile
24 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 50 later decisions — most recently December 2021 · most notably United States v. Arkison (1994), Stockmeier v. Angelone (1995)
24 federal appellate · 3 district · 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. § 7430 · 26 U.S.C. § 7431 · 28 U.S.C. § 2412 · 28 U.S.C. § 2680
Relies on Valley Forge Christian College v. Americans United for Separation of Church and State, Inc. · Allen v. Wright · Ohio Bureau of Employment Services v. Hodory · Bender v. Williamsport Area School District · Laird v. Tatum
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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In any administrative or court proceeding which is brought by or against the United States in connection with the determination, collection or refund of any tax, interest or penalty under this title....”
4 later decisions quote this exact passage · from the majority“in connection with the determination, collection, or refund of any tax,”
3 later decisions quote this exact passage · from the majority“brought solely to redress violations of their constitutional rights [and] simply ha[d] nothing to do with [their] taxes.”
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.