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← 26 TC 107 - Acker v. Commissioner

Acker v. Commissioner’s Empirical Analysis

1956

Citation profile

197
cited by 197 later decisions
February 2017
most recently cited

8 federal appellate ·

How this case has been cited

Cited by 197 later decisions — most recently February 2017 · most notably Beaver v. Commissioner (1970), Stoltzfus v. United States (1968)

8 federal appellate ·

12401956196019701980199020002010decided

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 Spies v. United States · Helvering v. Mitchell · Fuller v. Commissioner · Tobias Watkins · Jones 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 197 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “combined with a willful and positive attempt to defeat the statute or evade tax, in any manner or by any means,”
    2 later decisions quote this exact passage
  2. “is due to reasonable cause and not due to willful neglect”
    2 later decisions quote this exact passage
  3. “Section 294(d)(2) provides an addition to the tax for substantial underestimate of estimated tax. In G. E. Fuller, 20 T.C. 308 , we approved the regulation (Regs. 111, sec. 29.294-1(b)( 3)(A)), which provides that in the event of a failure to file the required declaration, the amount of the estimated tax for the purposes of the above-mentioned section is zero; and we there approved also the imposition of sanctions under both section 294(d)(2) and section 294(d)(1)(A). We here follow our decision in the Fuller case.”
    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.