Pack v. United States’s Empirical Analysis
992 F.2d 955 · 1993
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 23 later decisions — most recently December 2010
12 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
Applies 26 U.S.C. § 6213 · 26 U.S.C. § 6221 · 26 U.S.C. § 6224 · 26 U.S.C. § 6225 · 26 U.S.C. § 6230 · 26 U.S.C. § 6231 · 26 U.S.C. § 6601 · 26 U.S.C. § 7121
Relies on Ardestani v. Immigration & Naturalization Service · Shaw v. Barr · Dock v. American Telephone & Telegraph Technologies · Love v. United States · Zaentz 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.
“fraud or malfeasance, or misrepresentation of a material fact.”
2 later decisions quote this exact passage · from the majority“In the case of a déficiency ..., if a waiver of restrictions under section 6213(d) on the assessment of such deficiency has been filed, and if notice and demand by the Secretary for payment of such deficiency is not made within 30 days after the filing of such waiver, interest shall not be imposed on such deficiency for the period beginning immediately after such 30th day and ending with the date of notice and demand and interest shall not be imposed during such period on any interest with respect to such deficiency for any prior period.”
1 later decision quote this exact passage · from the majority“The taxpayer shall at any time (whether or not a notice of deficiency has been issued) have the right, by a signed notice in writing filed with the Secretary, to waive the restrictions provided in subsection (a) on the assessment and collection of the whole or any part of the deficiency.”
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.