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← 99 TC 475 - Allen v. Commissioner

Allen v. Commissioner’s Empirical Analysis

1992

Citation profile

23
cited by 23 later decisions
1
cited 1 times by the Supreme Court
July 2010
most recently cited

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 ·

210199220002010decided

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.

  1. “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
  2. “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
  3. “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.