Boynton v. Pedrick’s Empirical Analysis
228 F.2d 745 · 1955
Citation profile
22 federal appellate ·
How this case has been cited
Cited by 37 later decisions — most recently November 1995 · most notably Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal Revenue (1967), Vaira v. Commissioner (1971)
22 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
Relies on Gibbs & Hudson v. Commissioner · Boynton v. Pedrick · Young v. Commissioner of Internal Revenue · Moskin v. Johnson
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Negligence or intentional disregard of rules and regulations with respect to income or gift taxes. — If any part of any underpayment (as defined in subsection (c) (1)) of any tax imposed by subtitle A or by Chapter 12 of subtitle B (relating to income taxes and gift taxes) is due to negligence or intentional disregard to rules and regulations (but without intent to defraud), there shall be added to the tax an amount equal to 5 per cent of the underpayment.”
4 later decisions quote this exact passage · from the majority“If the court please, I except to your Honor's charge that if the plaintiff's failure to report was intentional, that he is liable for a penalty. Our position is that a man has the right to contest any of the Regulations of the Bureau of Internal Revenue, as long as it is done in good faith, and that he is not to be penalized for asserting his legal rights or asserting what he in good faith believes are his legal rights. I also except to your Honor's failure to charge the other requests filed by the plaintiff in his requests to charge and in his supplemental requests to charge, which have not been charged by the Court; and I also except to the failure of the Court to submit to the jury all the other questions of fact which appear in the record.”
1 later decision quote this exact passage · from the majoritye.g. Boynton v. Pedrick“Was the plaintiff's failure to report his income for the year, in the manner prescribed by law, due either to negligence or to intentional disregard of rules and regulations?”
1 later decision quote this exact passage · from the majoritye.g. Boynton v. Pedrick
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.