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← 98 F.3d 194 - Snap-Drape, Inc. v. Commissioner

Snap-Drape, Inc. v. Commissioner’s Empirical Analysis

98 F.3d 194 · 1996

Citation profile

62
cited by 62 later decisions
November 2023
most recently cited

24 federal appellate ·

How this case has been cited

Cited by 62 later decisions — most recently November 2023 · most notably Nieves-Villanueva v. Soto-Rivera (1997), Goodman v. Harris County (2009)

24 federal appellate ·

2801996200020102020decided

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. § 243 · 26 U.S.C. § 301 · 26 U.S.C. § 312 · 26 U.S.C. § 316 · 26 U.S.C. § 404 · 26 U.S.C. § 55 · 26 U.S.C. § 56 · 26 U.S.C. § 57

Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Allied Structural Steel Co. v. Spannaus · Rowan Cos. v. United States · Helvering v. R. J. Reynolds Tobacco Co. · Hoffa v. United States

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.

  1. “issued under a specific grant of authority to prescribe a method of executing a statutory provision,”
    2 later decisions quote this exact passage · from the majority
  2. “(1) whether or to what extent the taxpayer justifiably relied on settled prior law or policy and whether or to what extent the putatively retroactive regulation alters that law; (2) the extent, if any, to which the prior law or policy has been implicitly approved by Congress, as by legislative reenactment of the pertinent Code provisions; (3) whether retroactivity would advance or frustrate the interest in equality of treatment among similarly situated taxpayers; and (4) whether according retroactive effect would produce an inordinately harsh result.”
    1 later decision quote this exact passage · from the majority
  3. “testimony in the form of an opinion or inference otherwise admissible is not objectionable because it embraces an ultimate issue to be decided by the trier of fact.”
    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.