Allen v. Comm'r’s Empirical Analysis
2007
Citation profile
3 federal appellate ·
Relationships
Relies on Badaracco v. Commissioner · American Properties, Inc. v. Commissioner of Internal Revenue · American Properties, Inc. v. Commissioner · Estate of Hutchen Upshaw, Deceased, Ardenia Upshaw, Administratrix, and Ardenia Upshaw, Individually v. Commissioner of Internal Revenue, Estate of Hutchen Upshaw, Deceased, Ardenia Upshaw, Administratrix,petitioner-Appellant v. Commissioner of Internal Revenue · Lucia 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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The statute keys the extension to the fraudulent nature of the return, not to the identity of the perpetrator of the fraud,”
1 later decision quote this exact passage“[i]n the case of a false or fraudulent return with the intent to evade tax.”
1 later decision quote this exact passage“seeking to collect only the deficiency in tax from * * * [the taxpayer]”
1 later decision quote this exact passagee.g. Browning v. Comm'r
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.