Angle v. United States’s Empirical Analysis
996 F.2d 252 · 1993
Citation profile
9 federal appellate · 7 district · 1 state decisions
How this case has been cited
Cited by 26 later decisions — most recently November 2015 · most notably Dye v. United States (1997), Huerta v. Gonzales (2006)
9 federal appellate · 7 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. § 56 · 26 U.S.C. § 58 · 26 U.S.C. § 6511 · 26 U.S.C. § 7422
Relies on United States v. Dalm · Cole v. United States · Lewis v. Reynolds · United States v. Felt & Tarrant Manufacturing Co. · Tucker v. Alexander
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) No suit prior to filing claim for refund. No suit or proceeding shall be maintained in any court for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected "without authority, or of any sum alleged to have been excessive or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Secretary, according to the provisions of law in that regard, and the regulations of the Secretary established in pursuance thereof.”
2 later decisions quote this exact passage · from the majority“While the statutes authorizing refunds do not specifically empower the Commissioner to reaudit a return whenever repayment is claimed, authority therefor is necessarily implied. An overpayment must appear before refund is authorized. Although the statute of limitations may have barred the assessment and collection of any additional sum, it does not obliterate the right of the United States to retain payments already received when they do not exceed the amount which might have been properly assessed and demanded.”
1 later decision quote this exact passage · from the majoritye.g. Dye v. United States“set forth in detail each ground upon which a credit or refund is claimed and facts sufficient to apprise the Commissioner of the exact basis thereof.”
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.