Cross v. United States’s Empirical Analysis
311 F.2d 90 · 1962
Citation profile
7 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 17 later decisions — most recently July 1992
7 federal appellate · 1 district · 1 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. § 4261 · 26 U.S.C. § 6672
Relies on Rodriguez v. New York · United States v. Ohio Power Co. · Reinecke v. Spalding · Moog Industries, Inc. v. Federal Trade Commission · Greenwald v. Maryland
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In previous years, as already noted, taxpayer Cross had recognized the excise. He was led to renounce further acknowledgment by a casual conversation with an unidentified lawyer in Florida. Before denying the obligation, he obtained an opinion from the Internal Revenue Service. It advised him of the duty to collect. Taxpayer’s adoption of a different course, while by no means morally culpable, was deliberate. He preferred to take his chances in litigation. Though all in good faith, nonetheless he thereby ‘willfully’ failed to follow the statute. He does not escape the penalty.”
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.