Hindenlang v. C’s Empirical Analysis
Citation profile
14 federal appellate · 8 district ·
How this case has been cited
Cited by 105 later decisions — most recently August 2018 · most notably Swanson v. Comm'r (2003), United States v. Hatton (2000)
14 federal appellate · 8 district ·
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
Relies on Grogan v. Garner · Badaracco v. Commissioner · Zellerbach Paper Co. v. Helvering · Commissioner of Internal Revenue v. Lane-Wells Co · Germantown Trust Co. 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 105 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) it must purport to be a return; (2) it must be executed under penalty of perjury; (3) it must contain sufficient data to allow calculation of tax; and (4) it must represent an honest and reasonable attempt to satisfy the requirements of the tax law.”
14 later decisions quote this exact passage · from the majority“[A] Form 1040 is not a return if it no longer serves any tax purpose or has any effect under the Internal Revenue Code. A purported return filed too late to have any effect at all under the Internal Revenue Code cannot constitute “an honest and reasonable attempt to satisfy the requirements of the tax law.” Once the government shows that a Form 1040 submitted after an assessment can serve no purpose under tax law, the government has met its burden.”
10 later decisions quote this exact passage · from the majority“[I]f a document purporting to be a tax return serves no purpose at all under the Internal Revenue Code, such a document cannot, as a matter of law, qualify as an honest and reasonable attempt to satisfy the requirements of the tax law. Therefore the document is not a “return” for purposes of 11 U.S.C. § 523 (a)(1)(B).”
7 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.