Nos 12046-12049’s Empirical Analysis
Citation profile
13 federal appellate · 2 state decisions
How this case has been cited
Cited by 48 later decisions — most recently November 2004 · most notably Joseph A. Cirillo and Martha R. Cirillo v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Joseph A. Cirillo and Martha R. Cirillo (1963), Hicks Co. v. Commissioner (1971)
13 federal appellate · 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. § 7454
Relies on Holland v. United States · Spies v. United States · Cohan v. Commissioner · Railway Employes' Department v. Hanson · Thomas 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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Regarding the alleged over-ceiling payments for food and wages, there is only the self-serving testimony of Williams. It is uncorroborated by any receipts, checks or other documentary evidence. None of the recipients of the contended for over-ceiling payments was produced. Since the taxpayers failed to furnish the investigating Internal Revenue agents the information regarding the claimed over-ceiling payments, the government was under no obligation to negative this exculpatory evidence. Cf. Holland v. United States, 1954, 348 U.S. 121 , 135-136, 75 S.Ct. 127 , 99 L.Ed. 150 .” Masters v. Commissioner, 3 Cir., 1957, 243 F.2d 335 , 338.”
2 later decisions quote this exact passage · from the majority“There is hardly a more routine badge of income tax fraud than a double set of records”
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.