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← 12 TC 933 - Felix v. Commissioner

Felix v. Commissioner’s Empirical Analysis

1949

Citation profile

5
cited by 5 later decisions
December 1981
most recently cited

How this case has been cited

Cited by 5 later decisions — most recently December 1981

3019491950196019701980decided

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. § 181

Relies on Commissioner v. Tower · Lusthaus v. Commissioner · Parker 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Section 294 (d) (1) (B) provides an addition to the tax in the case of failure to pay an installment of estimated tax within the time prescribed, unless the failure is shown to the satisfaction of the Commissioner of Internal Revenue to be due to reasonable cause and not to willful neglect. That addition is -in the amount of 5 per cent of the unpaid part of the installment, plus an addition óf 1 per cent for each month (except the first) during which the installment remains' unpaid, but in no event to exceed 10 per cent of the unpaid part of’ the installment. Consequently, a taxpayer who failed to pay any part of an installment when due and for as much as six months thereafter would be liable for the maximum addition' of 10 per cent. ■”
    1 later decision quote this exact passage
  2. “* * * there shall be added to the tax 5 per centum of the unpaid amount of such installment, and in addition 1 per centum of such unpaid amount for each month (except the first) or fraction thereof during which such amount remains unpaid. * * * [Emphasis added.]”
    1 later decision 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.