Hackleman v. Granquist’s Empirical Analysis
1957
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 272 · 26 U.S.C. § 291 · 26 U.S.C. § 6651 · 26 U.S.C. § 6659
Relies on Fides, A. G. v. Commissioner · United States v. Erie Forge Co. · Blenheim Co. v. Commissioner of Internal Revenue · Taylor Secur., Inc. v. Commissioner · 124 F. Supp. 426 - Davis v. Dudley
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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““§ 6659. Applicable rules “(a) Additions treated as tax.— Except as otherwise provided in this title— “(1) The additions to the tax, additional amounts, and penalties provided by this chapter shall be paid upon notice and demand and shall be assessed, collected, and paid in the same manner as taxes; “(2) Any reference in this title to ‘tax’ imposed by this title shall be deemed also to refer to the additions to the tax, additional amounts, and penalties provided by this chapter. “(b) Additions to tax for failure to file return or pay tax. — Any addition under section 6651 or section 6653 to a tax imposed by another subtitle of. this title shall be considered a part of such tax for the purpose of applying the provisions of this title relating to the assessment and collection of such tax (including the provisions of subchapter B of chapter 63, relating to deficiency procedures for income, estate, and gift taxes).””
2 later decisions 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.