Halle v. Commissioner’s Empirical Analysis
175 F.2d 500 · 1949
Citation profile
68 federal appellate · 3 state decisions
How this case has been cited
Cited by 318 later decisions — most recently September 2018 · most notably DiLeo v. Commissioner (1991), Roberts v. Commissioner (1974)
68 federal appellate · 3 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.
Appellate journey
reviewedthe decision below (from New York Southern District Court)
Relationships
Applies 26 U.S.C. § 22 · 27 U.S.C. § 1
Relies on Welch v. Helvering · Cohan v. Commissioner · Burnet v. Houston · Old Mission Portland Cement Co. v. Helvering · Helvering v. Safe Deposit & Trust 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 318 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The federal income tax system is one of self-assessment by the taxpayer. Its efficiency must depend largely on the truth of facts set out by the taxpayer in his return. And, appropriately geared to the gravity of nondisclosure (or false disclosure), Congress has provided varied sanctions, both civil and criminal, to protect that system. Implicit in the working of the system is an obvious duty of keeping proper records imposed on the taxpayer. Nor must the fact be overlooked that the taxpayer here was no unlettered person, ignorant of the methods of business and the purlieus of the law, but, on the contrary, he was a successful lawyer, practicing under the keen competition that obtains in the largest city on this continent.””
2 later decisions quote this exact passage · from the majority“(b) Fkaud. — If any part of any deficiency is due to fraud with intent to evade tax, then 50 per centum of the total amount of the deficiency (in addition to such deficiency) shall be so assessed, collected, and paid, in lieu of the 50 per centum addition to the tax provided in section 3176 of the Revised Statutes, as amended.”
2 later decisions quote this exact passage · from the majority“bookmaker, " that he received proceeds from a winning bet placed on a Mohammed Ali fight in 1970, 5 and that he was indicted and convicted of narcotics trafficking for those same years. Petitioner also testified that he had no regular employment during the taxable years in issue and that no income from the above-mentioned illegal activities was reported on his income tax returns for the taxable years in issue. Accordingly, in light of respondent's persuasive evidence coupled with petitioner's testimony, we uphold respondent's determination with respect to petitioner's unreported income. The next issue for our consideration is whether any part of the underpayment of tax for each of the years here in issue is due to fraud with intent to evade tax. If we find that the underpayments of tax at issue herein are not due to fraud, such deficiencies are barred by the statute of limitations. Generally, the amount of any tax must be assessed within three years after a return is filed. Sec. 6501(a) . However, the tax may be assessed "at any time”
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.