Gouldman v. Commissioner’s Empirical Analysis
165 F.2d 686 · 1948
Citation profile
11 federal appellate ·
How this case has been cited
Cited by 27 later decisions — most recently July 2010 · most notably Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal Revenue (1967), Carlos v. Commissioner (1967)
11 federal appellate ·
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. § 22
Relies on Welch v. Helvering · Gregory v. Helvering · Helvering v. Clifford · Helvering v. Horst · Commissioner of Internal Revenue v. Court Holding Co
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The assessment of a negligence penalty is a purely administrative act dependent upon a finding of the extent of negligence.”
2 later decisions quote this exact passage · from the majority“though the penalty assessed was for negligence or intentional disregard of rules and regulations 27”
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.