Sanders v. Commissioner’s Empirical Analysis
1955
Citation profile
47 federal appellate · 5 district · 2 state decisions
How this case has been cited
Cited by 119 later decisions — most recently May 2015 · most notably United States v. Porth (1970), United States v. Daly (1973)
47 federal appellate · 5 district · 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. § 117
Relies on Federal Crop Ins Corporation v. Merrill · Spies v. United States · Botany Worsted Mills v. United States · United States v. Munsey Trust Co. · Hort 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 119 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“due to reasonable cause and not due to willful neglect,”
3 later decisions quote this exact passage · from the majority““(d) Additions to tax “(1) Failure to file return. In case of any failure to make and file a return or list within the time prescribed by law, or prescribed by the Commissioner or the collector in pursuance of law, the Commissioner shall add to the tax 25 per centum of its amount, except that when a return is filed after such time and it is shown that the failure to file it was due to a reasonable cause and not to willful neglect, no such addition shall be made to the tax: Provided, That in the case of a failure to make and file a return required by law, within the time prescribed by law or prescribed by the Commissioner in pursuance of law, if the last date so prescribed for filing the return is after August 30, 1935, then there shall be added to the tax, in lieu of such 25 per centum: 5 per centum if the failure is for not more than 30 days, with an additional 5 per centum for each additional 30 days or fraction thereof during which failure continues, not to exceed 25 per centum in the aggregate.” [Emphasis supplied.]”
2 later decisions quote this exact passage · from the majority“[T]heUnited States may not be estopped by the unauthorized acts of its agents nor may such agents waive the rights of the United States by their unauthorized acts.”
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.