Hammon v. United States’s Empirical Analysis
1990
Citation profile
2 state decisions
How this case has been cited
Cited by 16 later decisions — most recently September 2012
2 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. § 6671 · 26 U.S.C. § 6672 · 26 U.S.C. § 7501
Relies on Atlantic Richfield Co. v. Newman Oil Co. · Slodov v. United States · Mazo v. United States · White v. United States · Howard v. United States
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A showing of reckless disregard requires the coincidence of three elements: (1) the responsible person’s knowledge (or reason to know) of a risk that taxes will not be paid, (2) a reasonable opportunity to discover and remedy the problem, and (3) a failure to undertake the reasonable efforts to ensure payment.”
1 later decision quote this exact passage“improperly relied on the same management which historically caused repeated tax difficulties,”
1 later decision quote this exact passage“did not institute safeguards to ensure that tax delinquencies would not recur”
1 later decision quote this exact passage
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.