Robinson v. Commissioner’s Empirical Analysis
100 F.2d 847 · 1939
Citation profile
20 federal appellate · 2 district ·
How this case has been cited
Cited by 36 later decisions — most recently December 1992 · most notably Bergeron v. Mansour (1945), Joyce v. Gentsch (1944)
20 federal appellate · 2 district ·
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 Stone v. White · Stearns Co of Boston Mass v. United States · Alamo Nat. Bank v. Commissioner of Internal Revenue · Commissioner of Internal Revenue v. Liberty Bank & Trust Co. · Southern Abstract & Loan Co. v. Commissioner of Internal Revenue
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Equitable estoppel applies in tax cases when the following correlative facts are present: The taxpayer, by his conduct, which includes language, acts, or silence knowingly makes a representation or conceals material facts which he intends or expects will be acted upon by taxing officials in determining his tax, and the true or concealed material facts are unknown to the taxing officials or they lack equal means of knowledge with the taxpayer, and act on his representation or concealment and to retrace their steps on a different state of facts would cause the loss of taxes to the Government. A weighty factor in determining the application of the principle is the availability of the necessary facts to the parties involved.” 100 F.2d at 849 .”
4 later decisions quote this exact passage · from the majority“Taxation furnishes fertile soil for equitable estoppel to grow and thrive. The assessing officials must lean heavily on the information contained in the taxpayers’ returns. Since the taxpayer has such a broad discretion in his methods of keeping his accounts, and the bar of the statute of limitations falls so promptly against the Government and as he is afforded so many forums of redress before payment is required he should not be relieved of governmental actions by reasons of his representations or silence.”
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.