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← 32 BTA 1192 - Joseph v. Commissioner

Joseph v. Commissioner’s Empirical Analysis

1935

Citation profile

41
cited by 41 later decisions
July 2012
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 41 later decisions — most recently July 2012 · most notably William J. Drieborg and Laura D. Drieborg v. Commissioner of Internal Revenue, William J. Drieborg v. Commissioner of Internal Revenue (1955), Switzer v. Commissioner (1953)

2 federal appellate ·

120193519401950196019701980199020002010decided

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 Crooks v. Harrelson · L. Schepp Co. v. Commissioner · Nicholson v. Commissioner · Weil v. Commissioner · KERBAUCH 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “* * * Failure to contest an adjustment made in determining the deficiency is not proof of fraud. The Commissioner can not sustain his burden of proof on a fraud issue by statements made in his notice of deficiency. James Nicholson, 32 B.T.A. 977 . Those items must be disregarded in so far as the fraud issue is concerned.”
    2 later decisions quote this exact passage
  2. “⅜ * * His very inconsistency and indifference to the result indicate negligence and carelessness rather than fraudulent intent. * * *”
    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.