Hatfried, Inc. v. Commissioner’s Empirical Analysis
162 F.2d 628 · 1947
Citation profile
61 federal appellate · 8 district · 4 state decisions
How this case has been cited
Cited by 127 later decisions (1 by the Supreme Court) — most recently June 2017 · most notably United States v. Boyle (1985), Neonatology Assocs., P.A. v. Comm'r (2000)
61 federal appellate · 8 district · 4 state decisions
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. § 291 · 26 U.S.C. § 501
Relies on Caminetti v. United States · United States v. American Trucking Associations · Spies v. United States · United States v. Murdock · Dobson 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 127 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(2) to pay the amount shown as tax on any return specified in paragraph (1) on or before the date prescribed for payment of such tax (determined with regard to any extension of time for payment), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there 3hall be added to the amount shown as tax on such return 0.5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 0.5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate;”
3 later decisions quote this exact passage · from the majority““ * * * It is not the purpose of the law to penalize frank difference of opinion or innocent errors made despite the exercise of reasonable care. Such errors are corrected by the assessment of the deficiency of tax and its collection with interest for the delay. * * * ””
1 later decision quote this exact passage · from the majority““Courts are reluctant to construe a statute so as to impose a penalty, unless there has been a substantial delinquency. * * * ””
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.