Boren v. Tucker’s Empirical Analysis
239 F.2d 767 · 1956
Citation profile
82 federal appellate · 6 district · 4 state decisions
How this case has been cited
Cited by 135 later decisions (3 by the Supreme Court) — most recently November 1996 · most notably Donaldson v. United States (1971), United States v. National Bank (1978)
82 federal appellate · 6 district · 4 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. § 6653 · 26 U.S.C. § 7602 · 26 U.S.C. § 7604 · 26 U.S.C. § 7605
Relies on Helvering v. Mitchell · Helvering v. Mitchell · 118 F. Supp. 248 - United States v. O'CONNOR · Martin v. Chandis Securities 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 135 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[f]or the purpose of ascertaining the correctness of any return, making a return where none has been made, determining the liability of any person for any internal revenue tax * * *.”
3 later decisions quote this exact passage · from the majority““(1) civil liability for the correct tax, (2) liability for the tax plus penalty, (3) criminal prosecution, or (4) both the penalty and the criminal prosecution.””
2 later decisions quote this exact passage · from the majority“In truth, we presume the `Secretary or his delegate' would be unfaithful to his statutory responsibilities if in every examination, once an incorrect return has been demonstrated or established, he did not come to some preliminary conclusion as to whether there existed facts sufficient upon which to base a possible criminal prosecution, without coming to any conclusion as to whether there should be a criminal prosecution.”
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.