Allen v. Commissioner’s Empirical Analysis
1992
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 23 later decisions (1 by the Supreme Court) — most recently July 2010
3 federal appellate ·
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
Relies on White v. Commissioner · Hosking v. Commissioner · Domtar Newsprint Sales Ltd. v. United States · Berry v. Commissioner · Galuska v. Commissioner
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“shall be filed by the taxpayer within 3 years from the time the return was filed or 2 years from the time the tax was paid, whichever of such periods expires the later, or if no return was filed by the taxpayer, within 2 years from the time the tax was paid.”
2 later decisions quote this exact passage“the credit or refund shall not exceed the portion of the tax paid during the 2 years immediately preceding the filing of the claim.”
2 later decisions quote this exact passage · from the majority“if on the date of the mailing of the notice of deficiency a claim had been filed (whether or not filed)”
2 later decisions quote this exact passage
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.