United States v. Knottnerus’s Empirical Analysis

Citation profile

3 federal appellate ·

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

1. “The IRS’ voluntary disclosure practice is not an amnesty or a grant of immunity from prosecution. While the IRS will not assure that it would never, under any circumstances, recommend the criminal prosecution of an individual who comes forward voluntarily to report the failure to file of one or more tax returns, the IRS’ practice has been not to do so where the person: a. informed the IRS that he/she has not filed tax returns for one of [sic] more taxpayer periods; b. had only legal source income, in other words no part of the income was earned from activity which is illegal under federal or state law; c. made the disclosure prior to being contacted by the IRS — in this context, “contact by the IRS” means that the taxpayer and/or the taxpayer’s representative has received notification by the IRS by a telephone call, letter or per sonal visit that the taxpayer is under criminal investigation; d. either filed a true and correct tax return or cooperated with the IRS in ascertaining the correct tax liability; and, e. either paid in full the amount due or, in those situations where the taxpayer was unable to make full payment, made bona fide arrangements to pay.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Klein

2. “An agency's failure to follow its own regulations does not rise to the level of a constitutional violation unless the regulations themselves are compelled by the Constitution.”

   1 later decision quote this exact passage · from the majority
   e.g. Sierra Resources, Inc. v. Herman