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← 108 F.2d 656 - Moore v. Cleveland Ry. Co.

Moore v. Cleveland Ry. Co.’s Empirical Analysis

108 F.2d 656 · 1940

Citation profile

22
cited by 22 later decisions
3
cited 3 times by the Supreme Court
2
states following
July 2016
most recently cited

6 federal appellate · 3 state decisions

How this case has been cited

Cited by 22 later decisions (3 by the Supreme Court) — most recently July 2016

6 federal appellate · 3 state decisions

6019401950196019701980199020002010decided

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. § 271 · 26 U.S.C. § 272

Relies on McCarthy Co. v. Commissioner · Mutual Lumber Co. v. Poe · Mutual Lumber Co. v. Poe · East Bay Water Co. v. McLaughlin · Hartford-Connecticut Trust Co. v. United States

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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““Waiver is hereby made of the restrictions imposed by § 57 of the Income Tax Act and consent is given to the assessment and collection of the following tax deficiency: Taxable year ending in 1950: Tax $27, 982. 83 Plus: Interest at 6 per cent annually on the deficiency as of the date prescribed for the payment of the first instalment up to the date payment is tendered -,- Penalties: 5 per cent on the deficiency owing to negligence or intentional disregard of the rules and regulations, but without intention to commit- fraud - 5 per cent on the tax for each month or fraction thereof of delay in filing - Total tax, interest, and penalties $- (Sgd.) - Taxpayer Address Date”
    1 later decision quote this exact passage · from the majority
  2. ““(d) Waiver of restrictions. The taxpayer shall at any time have the right, by a signed notice in writing filed with the Commissioner, to waive the restrictions provided in subsection (a) of this section on the assessment and collection of the whole or any part of the deficiency.””
    1 later decision quote this exact passage · from the majority
  3. ““It would seem, therefore, that whenever the taxpayer has failed to make adequate return of income, there is a deficiency, notwithstanding lack of determination by the Commissioner or his agents.””
    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.