United States v. Shavin’s Empirical Analysis
320 F.2d 308 · 1963
Citation profile
22 federal appellate · 2 state decisions
How this case has been cited
Cited by 40 later decisions — most recently July 2019 · most notably Brooks v. Commissioner (1984), United States v. Sorrentino (1984)
22 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. § 7201
Relies on Foti v. Immigration & Naturalization Service · United States v. E. I. du Pont de Nemours & Co. · Fanchon & Marco, Inc. v. Paramount Pictures, Inc. · Dalehite v. United States · De Moss 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The taxpayer’s costs and other factors which would lessen his tax liability are peculiarly within his own knowledge. Accordingly, the law has placed upon him the burden of going forward with the evidence once the Government has established receipts in excess of those reported in his income tax return. * * * “This rule is grounded on the realization that it would be virtually impossible for the Government to show the negative fact that a taxpayer had no unreported deductions or exclusions. In such a case the Government, having shown unreported income, is aided by the presumption that the deductions and exclusions listed by a taxpayer in his return are all that exist.””
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.