Compton v. United States’s Empirical Analysis
334 F.2d 212 · 1964
Citation profile
30 federal appellate · 4 district · 2 state decisions
How this case has been cited
Cited by 65 later decisions (1 by the Supreme Court) — most recently May 2017 · most notably United States v. Janis (1976), Pizzarello v. United States (1969)
30 federal appellate · 4 district · 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. § 4401 · 26 U.S.C. § 4411 · 26 U.S.C. § 6862 · 26 U.S.C. § 7421 · 28 U.S.C. § 2201
Relies on Elkins v. United States · Silverthorne Lumber Co. v. United States · Helvering v. Taylor · Enochs v. Williams Packing & Navigation Co. · Walder 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 65 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If the burden of proof goes so far as to demand not only that the taxpayer show that the deficiency assessed against him is wrong, but what is the proper deficiency, or that there should be none at all, the decision was right, even though we know that the tax is too high. In an action to recover taxes unlawfully collected the burden does go so far ... But the reason for this is obvious; a plaintiff, seeking an affirmative judgment mea sured in dollars, must prove how much is due. His claim is for money paid and he must show that every dollar he recovers is unjustly withheld. So it is not enough merely to prove that the tax as a whole was unlawful; some of the dollars he paid may nevertheless have been due.”
1 later decision quote this exact passage · from the majority““By alleging in her complaint that she was not engaged in accepting wagers, she recognized that this question would materially affect her right to a refund of taxes paid. Her allegations were denied. The burden was on the plaintiff to prove that she was not engaged in accepting wagers during the period in question. * * * Even assuming that the assessment was thereby rendered invalid, plaintiff could not recover without a further showing that she did not in fact owe all or some part of the amount collected. Her attempt to do so failed when the District Court rejected her testimony that she had not been engaged in the numbers business during the period in question.””
1 later decision quote this exact passage · from the majority“An action for refund of taxes paid is in the nature of an action of assumpsit for money had and received and the plaintiffs right to recover must be measured by equitable standards. Here, taxpayer’s entire liability is at issue and if, under any state of facts, the Government is entitled to the money claimed, she cannot prevail. Consequently, it is not enough merely to show that the assessment was invalid or that the Commissioner erred; the plaintiff must go further and produce evidence from which another and proper determination can be made.”
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.