Bennett v. Commissioner’s Empirical Analysis
1958
Citation profile
13 federal appellate ·
How this case has been cited
Cited by 76 later decisions (1 by the Supreme Court) — most recently July 2015 · most notably Badaracco v. Commissioner (1984), Beaver v. Commissioner (1970)
13 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 Holland v. United States · Illinois ex rel. Kennedy v. Hurley · Wells v. Simonds Abrasive Co. · Acker v. Commissioner · Lipsitz 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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““For, once a nonfraudulent return is filed, putting the Commissioner on notice of a taxpayer’s receipts and deductions, there can be no policy in favor of permitting assessment thereafter at any time without limitation. We think that the statute of limitations begins to run with the filing of such returns.””
3 later decisions quote this exact passage“Any other result would make sport of the so-called fraud penalty. A taxpayer who had filed a fraudulent return would merely take his chances that the fraud would not be investigated or discovered, and then, if an investigation were made, would simply pay the tax which he owed anyhow and thereby nullify the fraud penalty. We think Congress has provided no such magic formula to avoid the civil consequences of fraud. * * *”
1 later decision quote this exact passage“to avoid the civil consequences of fraud where no return at all had originally been filed while at the same time withholding it from those who had originally filed a false return. We think a fair and reasonable construction of the revenue laws requires that both situations be treated alike.”
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.